Jessy Duenas Hernandez v. County of Los Angeles

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

12 JESSY DUENAS HERNANDEZ No. 2:21-CV-03937-MWF (AFMx)

DISCOVERY MATTER

Plaintiff, v. [PROPOSED] STIPULATED PROTECTIVE ORDER

GOVERNING PRODUCTION OF

COUNTY OF LOS ANGELES, by and “CONFIDENTIAL” through the LOS ANGELES COUNTY INFORMATION SHERIFF’S DEPARTMENT;

DEPUTY VILANOVA; DEPUTY [Assigned to Hon. Michael W. SANDOVAL; DEPUTY GERMAN Fitzgerald, Courtroom 5A] ZAMBRANO; DEPUTY RAUL [Discovery Document: Referred to the ALVAREZ; DOES 1-25, inclusive, Hon. Alexander F. MacKinnon, Magistrate Judge] Defendants

I. PURPOSE AND LIMITATIONS

II. Discovery in this action is likely to involve production of confidential or

25 private information for which special protection from public disclosure 26 and from use for any purpose other than prosecuting this action may be 27 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following…