Felicia Cherie Taylor v. Rausch, Sturm, Israel, Enerson and Hornik LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

6

FELICIA CHERIE TAYLOR, an Case No. 19-cv-08123-ODW-RAO individual,

Plaintiff,

STIPULATED PROTECTIVE

11 vs. ORDER1

RAUSCH, STURM, ISRAEL

ENERSON & HORNIK LLC, a Wisconsin limited liability company; 15 CAMRYN P. BERK, an individual; and DOES 1-10, inclusive

19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public disclosure 22 and from use for any purpose other than prosecuting this litigation may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the 24 following Stipulated Protective Order. The parties acknowledge that his Order does 25 not confer blanket protections on all disclosures or responses to discovery and that the

27 1 This Stipulated Protective Order is substantially based on the model protective order provided under 28 Magistrate Judge Rozella A. Oliver’s Procedures -1-…