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 principles, and it does not presumptively entitle parties to file confidential information under seal.Ģ. The parties represent and acknowledge that this agreement does not confer blanket protection on all disclosures or responses to discovery. The loss or unrestricted disclosure of such can result in substantial harm to individuals, including identity theft or other fraudulent use of the information. Discovery in this action is likely to involve production of confidential, proprietary, personally identifiable, sensitive personal, or private information for which special protection may be warranted. The parties hereby stipulate to and request the court to enter the following agreement as a Stipulated Protective Order under Federal Rules of Civil Procedure 5(e) and 26(c).ġ.
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