Experience Hendrix, L.L.C. v. Andrew Pitsicalis

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

9

Case No. 2:21-cv-03362-PSG- RAO Experience Hendrix, LLC et al., Plaintiff, STIPULATED PROTECTIVE

ORDER1

v. Andrew Pitsicalis, Defendant. 16 17 1. A. PURPOSES AND LIMITATIONS 18 Discovery in this action is likely to involve production of confidential, 19 proprietary or private information for which special protection from public 20 disclosure and from use for any purpose other than prosecuting this litigation and 21 collecting the $2 million judgment entered against Andrew Pitsicalis by the 22 Southern District of New York on October 21, 2019 (the “Judgment”) may be 23 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 24 enter the following Stipulated Protective Order. The parties acknowledge that this 25 Order does not confer blanket protections on all disclosures or responses to 26 27 discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal…