Cityscape Rentals, LLC v. Travelers Casualty Insurance Company of America ( 2019 )

NE SLI II IPR IDOE EI ELEM AD EGS AME RM TAGE NTE □□□ 3 5 7 UNITED STATES DISTRICT COURT □ 8 CENTRAL DISTRICT OF CALIFORNIA ° CITYSCAPE RENTALS, LLC, a Case No. 2:19-cv-01886-DSF-E 10 || California limited liability company, Assigned to Hon. Dale S. Fischer 11 Plaintiffs, STIPULATED PROTECTIVE vs. ORDER 13 || TRAVELERS CASUALTY 14 AMERICA: YOUNG & OF Complaint Filed: February 6, 2019 15 ASSOCIATES: PARRY through 30, Action Removed: March 14, 2019 16 inclusive, Defendants, Trial Date: None Set 17 18 19 20 22 23 || 1. A. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 || proprietary or private information for which special protection from public 26 || disclosure and from use for any purpose other than prosecuting this litigation may 27 || be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 28 || enter the following Stipulated Protective Order. The parties acknowledge that this □□□□□□□□□□□□□□□□□□□□□□□ Document Filed idizaiid rage □ orio Page IV #205 1 || Order does not confer blanket protections on all disclosures or responses to 2 || discovery and that the protection it affords from public disclosure and use extends 3 || only to the limited information or items that are entitled to confidential treatment 4 || under the applicable legal principles. 5 B. GOOD CAUSE STATEMENT 6 This action is likely to involve commercial, financial, technical and/or __ 7 || proprietary information for which special protection from public disclosure and 8 || from use for any purpose other than prosecution of this action is warranted. Such 9 || confidential and proprietary materials and information consist of, among other 10 || things, confidential business or financial information, information regarding 11 || confidential business practices, or other confidential commercial information 12 || (including information implicating privacy rights of third parties), information 13 || otherwise generally unavailable to the public, or which may be privileged or 14 || otherwise protected from disclosure under state or federal statutes, court rules, case 15 || decisions, or common law.. Accordingly, to expedite the flow of information, to 16 || facilitate the prompt resolution of disputes over confidentiality of discovery 17 || materials, to adequately protect information the parties are entitled to keep 18 || confidential, to ensure that the parties are permitted reasonable necessary uses of 19 || such material in preparation for and in the conduct of trial, to address their handling 20 || at the end of the litigation, and serve the ends of justice, a protective order for such 21 || information is justified in this matter. It is the intent of the parties that information 22 || will not be designated as confidential for tactical reasons and that nothing be so 23 || designated without a good faith belief that it has been maintained in a confidential, 24 || non-public manner, and there is good cause why it should not be part of the public 25 || record of this case. . 26 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 27 The parties further acknowledge, as set forth in Section 12.3, below, that this 28 || Stipulated Protective Order does not entitle them to file confidential information □□□□□□□□□□□□□□□□□□□□□□□ Document