Rehamn Youssef v. T-Mobile USA, Inc

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

10 11 REHAMN YOUSSEF, Case No. 5:20-cv-02016 JWH (PVCx) 12 Plaintiff, STIPULATED PROTECTIVE 13 ORDER v. 14

T-MOBILE USA, INC., AND DOES 1

15 THROUGH 30, 16 Defendants. 17 18 19 20 21 22 23 24 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the 6 Court to enter the following Stipulated Protective Order. The parties 7 acknowledge that this Order does not confer blanket protections on all 8 disclosures or responses to discovery and that the protection it affords from 9 public disclosure and use extends only to the limited information or items that 10 are entitled to confidential treatment under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve medical records,…