Edward Heldman III v. Larry Zerner

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

EDWARD HELDMAN III, AN ) Case No. 2:19-CV-08185-MCS- INDIVIDUAL; COMEDYMX, INC., ) MAR

A NEVADA CORPORATION; )

COMEDYMX, LLC, A DELAWARE ) [PROPOSED] STIPULATED

LIMITED LIABILITY COMPANY; ) DISCOVERY PROTECTIVE ) ORDER 15 Plaintiff, ) ) v. ) 17 ) LARY ZERNER ) ) 19 Defendant. ) ) 21 ///

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24 /// 25 26 27 1. A. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or…