Michael Thai v. Team Industrial Services, Inc.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 MICHAEL THAI, an individual, on behalf of himself and on behalf of all Case No. 2:21-cv-03319-FLA-GJS others similarly situated, 12 Plaintiff, [PROPOSED] STIPULATED PROTECTIVE ORDER1 v.

TEAM INDUSTRIAL SERVICES,

INC., a Corporation; and Does 1 through 50 Inclusive, 16 Defendants. 17 18 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 Order does not confer blanket protections on all disclosures or responses to

1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Gail J. Standish’s Procedures. 1 …