Brooke Fortson v. City of Los Angeles

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 BROOKE FORTSON, Case No. CV21-00384 CJC (GJSx)

Plaintiff, STIPULATED PROTECTIVE

ORDER1

v.

CITY OF LOS ANGELES, A

MUNICIPAL ENTITY; CHIEF

MICHEL MOORE; AND DOES 1- 10, INCLUSIVE,

18 Defendants.

20 1. A. PURPOSES AND LIMITATIONS 21 Discovery in this action is likely to involve production of confidential, 22 proprietary or private information for which special protection from public 23 disclosure and from use for any purpose other than prosecuting this litigation may 24 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 25 enter the following Stipulated Protective Order. The parties acknowledge that this 26 27 Order does not confer blanket protections on all disclosures or responses to 1 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the applicable legal principles.

B. GOOD CAUSE STATEMENT

5 This…