Maria Salas v. City of Garden Grove

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UNITED STATES DISTRICT COURT

9 10 CENTRAL DISTRICT OF CALIFORNIA 11 MARIA SALAS, NOEL SALAZAR, Case No.: 2:20-cv-11422 and M.J.S. minor, by and through 12 his Guardian Ad Litem , MARY STIPULATION RE: PROTECTIVE 13 ANN D’AMBRA, ORDER 14 Plaintiffs, 15 [DISCOVERY DOCUMENT; v. REFERRED TO MAGISTRATE 16

JUDGE ]

17 CITY OF GARDEN GROVE,

DOES 1 THROUGH 10,

18

INCLUSIVE,

19 Defendants. 20 21 22 23 24 25 26 27 1 Plaintiffs MARIA SALAS, NOEL SALAZAR, and M.J.S. minor, by and 2 through his Guardian Ad Litem, MARY ANN D’AMBRA and Defendant CITY OF 3 GARDEN GROVE, a public entity, by and through their respective counsel, hereby 4 stipulate and agree as follows: 5 1. PURPOSES AND LIMITATIONS 6 Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public 7 disclosure and from use for any purpose other than prosecuting this litigation may 8 be warranted. 9 Accordingly, the parties hereby stipulate to and petition the Court to enter the 10 following…