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Groce v. Red Carpet Couriers, LLC

United States District Court, E.D. North Carolina, Western Division

January 25, 2017

JEFFREY LYNN GROCE, Plaintiff,
v.
RED CARPET COURIERS, LLC and RONALD KEITH WATTS, Defendants.

          WE REQUEST AND CONSENT TO THE FOREGOING: Michael D. Maurer N.C. State Bar No. 43466 Attorneys for Plaintiff

          Marc C. Tucker N.C. State Bar No. 25722 Smith Moore Leatherwood LLP Attorneys for Defendants

          CONSENT PROTECTIVE ORDER

          JAMES C. DEVER III Chief United States District Judge

         The parties assert that they possess information relating to the subject matter of this action that they may deem confidential and proprietary. The parties recognize that in the course of discovery proceedings relating to this action, it may be necessary to disclose certain of the asserted confidential and proprietary information. The parties wish to ensure that such confidential and proprietary information will not be disclosed to unauthorized persons, and will not be used for any purpose other than this litigation.

         With the consent and upon the request of all parties, through their respective counsel, as shown by their signatures below, it is hereby ORDERED by the Court that pursuant to Rule 26(c) of the Federal Rules of Civil Procedure the following restrictions and procedures shall apply to protect the confidentiality of certain documents that may be produced in this litigation. For good cause shown, the Court hereby approves and enters the following Protective Order:

         1. This Order does not control any issues of privilege or work-product that may be asserted by a party during the pendency of this litigation. Each party bears the burden of raising and/or meeting any assertions of privilege or work-product protection pursuant to the Federal Rules of Civil Procedure and applicable case law separate and apart from the issues of confidentiality addressed in this Order.

         2. Prior to its production, any party may designate documents or other materials as containing CONFIDENTIAL INFORMATION to be protected by this Order. For purposes of this Order, "Confidential Information or Material" shall be defined as any information or materials - whether in hardcopy, electronic or any other format - that a party has a legitimate and good faith interest and basis in keeping free from public disclosure.

         3. The following "Qualified Persons" are entitled to review and utilize documents or materials containing confidential information produced pursuant to the terms of this Order, subject to any limitations in this Order:

a. The parties, their employees, and their attorneys of record (including their necessary staff);
b. Independent expert witnesses who have been specially employed or retained to assist in this litigation and their necessary staff;
c. Fact witnesses who are asked to review confidential information during the course of a deposition or trial in this litigation;
d. Court reporters recording testimony in this litigation and their necessary staff;
e. The presiding Judge, courtroom clerk or other necessary court personnel, and jurors (upon being sworn in) at any motion hearing or trial of this matter; and
f. Any other person who is later designated as a Qualified Person by Order of the Court or ...

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