Securities and Exchange Commission v. Criterion Wealth Management Insurance Services, Inc.

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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10 SECURITIES AND EXCHANGE Case No. 2:20-cv-01402-ODW- COMMISSION, (JEMx) 11 Plaintiff, STIPULATED PROTECTIVE 12 ORDER vs. 13

CRITERION WEALTH

14 MANAGEMENT INSURANCE SERVICES, INC., et al. 15 Defendants. 16 17 18 1. PURPOSES AND LIMITATIONS 19 Defendants believe that discovery in this action is likely to involve 20 production of confidential, proprietary, or private information for which special 21 protection from public disclosure and from use for any purpose other than 22 prosecuting this litigation may be warranted. Specifically, Defendants believe that 23 certain information obtained or which Defendants seek to obtain from one or more 24 third parties may warrant the protections set forth in this Order. Plaintiff Securities 25 and Exchange Commission (“SEC”) takes the position that when considering 26 whether good cause for a protective order under Rule 26(c) exists, courts must 27 weigh the presumption of openness of litigation materials against the asserted right 28 of confidentiality. …