Bobby Harris v. Nissan North America, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

11 BOBBY HARRIS, individually and on Case No. 2:20-cv-06021-CJC(GJSx) behalf of all others similarly situated,

CLASS ACTION

Plaintiff,

vs. STIPULATED PROTECTIVE ORDER1

NISSAN NORTH AMERICA, INC,

15 and DOES 1 through 10, inclusive,

16 Defendants.

19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public 22 disclosure and from use for any purpose other than prosecuting this litigation may 23 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 enter the following Stipulated Protective Order. The parties acknowledge that this 25 Order does not confer blanket protections on all disclosures or responses to 26 27 1 This Stipulated Protective Order is substantially based on the model protective discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to…