Shahrooz Sabzehroo v. Capital One Bank (USA), N.A.
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 CASE NO. 2:20-cv-10615-FMO-GJS SHAHROOZ SABZEHROO, individually and on behalf of all others similarly situated, [PROPOSED] STIPULATED PROTECTIVE ORDER1 Plaintiff,
vs.
CAPITAL ONE BANK (USA), N.A.
17 and DOES 1 through 10 inclusive, 18 Defendants.
21 22 23 24 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective Plaintiff Shahrooz Sabzehroo (“Plaintiff”) and Defendant Capital One Bank (USA), N.A. (“Defendant”) (collectively, the “Parties”), in order to facilitate the exchange of information and documents that may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, and in order to secure the entry of a protective order limiting the review, copying, dissemination and filing of confidential and/or proprietary documents and information to be produced by the Parties and their respective counsel or by any non- …