Order Regarding Protection of Confidential Information [ECF No. 75] Motion — In re BofA Unemployment Litigation (Dkt. 76)

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An Order Regarding Protection of Confidential Information in In re: Bank of America California Unemployment Benefits Litigation, Case 3:21-md-02992-GPC-MSB in the U.S. District Court for the Southern District of California, filed 09/14/21 as Document 76 and dated September 14, 2021. Entered on a stipulation between Bank of America and the individual plaintiffs represented by interim liaison counsel, it binds those plaintiffs to the proposed protective order pending its entry, or to any different order the court enters. The stated purpose is to allow production of documents containing confidential information, and plaintiffs' counsel promise not to disclose or use anything the bank produces except as the protective order allows.

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Case No. 21md2992-LAB (MSB)
ORDER RE: STIPULATION REGARDING PROTECTION OF CONFIDENTIAL 
INFORMATION  
 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF CALIFORNIA  
SAN DIEGO DIVISION 
IN RE: BANK OF AMERICA 
CALIFORNIA UNEMPLOYMENT 
BENEFITS LITIGATION 
Case No. 21md2992-LAB (MSB) 
 
ORDER REGARDING 
PROTECTION OF 
CONFIDENTIAL INFORMATION  
[ECF No. 75] 
 
 
Defendant Bank of America (“BANA”) and the Individual Plaintiffs 
represented by Interim Liaison Counsel for the Individual Plaintiffs (collectively 
the “Parties”), have stipulated and agreed as follows: 
1.  
The Individual Plaintiffs represented by Interim Liaison Counsel agree 
to be bound by the terms of the Proposed Protective Order, pending its approval 
and entry by the Court.   
2. 
In the event that the Court modifies the Proposed Protective Order, or 
in the event that the Court enters a different Protective Order, the Individual 
Plaintiffs represented by Interim Liaison Counsel for the Individual Plaintiffs agree 
Case 3:21-md-02992-GPC-MSB     Document 76     Filed 09/14/21     PageID.473     Page 1
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Case No. 21md2992-LAB (MSB)
ORDER RE: STIPULATION REGARDING PROTECTION OF CONFIDENTIAL INFORMATION  
 
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to be bound by the Proposed Protective Order until such time as the Court may 
enter such different Order.  
3. 
The intent of this agreement is to allow for the production of 
documents with confidential information under the terms of the Proposed Protective 
Order, pending its entry (or the entry of a different protective order). 
4. 
Counsel for Individual Plaintiffs solemnly promise and represent that 
they will not disclose or use in any manner any information or item produced by 
BANA except in strict compliance with the provisions of the Proposed Protective 
Order (or with any other protective order to be entered by the Court). 
PURSUANT TO STIPULATION, IT IS SO ORDERED. 
Dated:  September 14, 2021 
 
 
Case 3:21-md-02992-GPC-MSB     Document 76     Filed 09/14/21     PageID.474     Page 2
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