Zahra Shahim v. Valor Healthcare, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION

10 11 ZAHRA SHAHIM, an individual, Case No. 8:21-cv-00435 DOC (JDEx) 12 Plaintiff, STIPULATION AND PROPOSED PROTECTIVE ORDER v. 14 VALOR HEALTHCARE, INC., and Complaint Filed: February 3, 2021 DOES 1 to 50, inclusive, Trial Date: None Set District Judge: Hon. David O. Carter Defendants. Magistrate Judge: Hon. John D. Early

17 IT IS HEREBY STIPULATED by and between Plaintiff ZAHRA SHAHIM (“Plaintiff”) and Defendant VALOR HEALTHCARE, INC. (“Defendant”) (collectively, “Parties”) that in order to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, the Local Civil Rules, and privacy rights, the Parties stipulate as follows: 1. PURPOSES AND LIMITATIONS Discovery in this action involves the production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other…