Klauber Brothers, Inc. v. Urban Outfitters, Inc.

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 KLAUBER BROTHERS, INC. Case No. 2:20-cv-07430-AB-AFM 13 Plaintiff, 14 v. STIPULATED PROTECTIVE 15 ORDER1 16 URBAN OUTFITTERS, INC.; et al., 17 Defendants. 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 disclosure 22 and from use for any purpose other than prosecuting this litigation may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 24 Stipulated Protective Order. The parties acknowledge that this Order does not confer 25 blanket protections on all disclosures or responses to discovery and that the protection 26 27 1 This Stipulated Protective Order is based substantially on the model protective order 1 it affords from public disclosure and use extends only to the limited information or 2 items that are entitled to…