Eren Pamir v. Designed Receivable Solutions, Inc.

1

2

3

4

5

6

7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10

11 EREN PAMIR Case No. 2:20-cv-9782-MCS-GJS

12 Plaintiff, [PROPOSED] PROTECTIVE 13 v. ORDER1

14 DESIGNED RECEIVABLE

SOLUTIONS, INC., CEDARS-

15 SINAI MEDICAL CENTER,

TRANSUNION, LLC, EXPERIAN

16 INFORMATION SERVICES, INC. 17 Defendant.

18

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 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the…