Peter T. Erdelyi and Associates v. Optimum Seismic, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

PETER T. ERDELYI & ASSOCIATES, a Case No.: 2:20-cv-11066-JVS-GJSx California Corporation, 12 Plaintiff, [PROPOSED] STIPULATED PROTECTIVE ORDER vs. 14 OPTIMUM SEISMIC, INC., a California Corporation, and DOES 1-10,

Defendants.

17 18 OPTIMUM SEISMIC, INC., a California Corporation,

Third-Party Plaintiff,

v. KMS STRUCTURAL DESIGN, INC., a California Corporation, KAMALEDDIN M. SADEGHI, an individual, dba KMS STRUCTURAL DESIGN ENGINEERS, and

ROES 1-5,

24 Third-Party Defendants. 25

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 …