Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

North Carolina Farm Bureau Mutual Insurance Company v. Onesource Water, LLC

United States District Court, E.D. North Carolina

March 28, 2017

NORTH CAROLINA FARM BUREAU MUTUAL FNSURANCE COMPANY AS SUBROGEE OF SANDY STARLING AND CHESTER STARLING, JR., Plaintiff,
v.
ONESOURCE WATER, LLC and WATERLOGIC COMMERCIAL PRODUCTS, LLC, Defendants.

          M. Caroline Trautman Counsel for Plaintiff North Carolina Farm Bureau Mutual Insurance Company as Subrogee of Sandy Starling and Chester Starling, Jr.

          J. Matthew Little Counsel for Defendant OneSource Water, LLC

          John I. Malone, Jr. Counsel for Defendant Waterlogic Commercial Products, LLC

          STIPULATION

          LOUISE W. FLANAGAN United States District Court Judge

         WHEREAS, the undersigned parties anticipate that documents and information produced in this litigation may contain or constitute confidential information and the parties wish to expedite and facilitate the production of such information;

         WHEREAS, the litigation involves claims that a product manufactured by one of the defendants was the cause of a fire that resulted in damage to the Starling residence. The proprietary design and manufacture of the product may become an issue that is litigated in this action, and therefore, the parties desire that any such proprietary and confidential business information not be made public beyond the need for such information in this lawsuit.

         NOW THEREFORE, it is hereby stipulated and agreed among the undersigned parties, acting through their duly authorized counsel, as follows:

         1. The following definitions shall apply to this Stipulated Protective Order:

a. As used herein, the term "CONFIDENTIAL INFORMATION" shall mean all information, documents, materials and tangible items, in whatever form produced, that a producing party in good faith believes contains, reflects, or concerns its non-public, confidential, commercially sensitive, proprietary, or trade secret information which, if disclosed, could cause the producing party injury or prejudice. Confidential information may not be used or disseminated except as provided in this Protective Order.
b. As used herein, the phrase "prosecution and/or defense of this action" shall mean preparation for trial of this action, including specifically, but not exclusively, pre-trial discovery pursuant to the Federal Rules of Civil Procedure, trial of this action, any alternative dispute resolution in this action, including but not limited to mediation, and preparation for, participation in, and prosecution and defense of, any appeal, rehearing, review or other judicial proceeding which relates to the subject matter of this action

         2. Each party shall designate any material it deems to be "Confidential" in the following manner:

i. By stamping all documents with the designation "Confidential",
ii. By imprinting the designation "Confidential" next to each answer to interrogatory, response to deposition upon written question, or response to request for admission,
iii. All deposition transcripts shall be confidential and accorded the protections set forth herein upon the designation in writing by a party seeking to keep the transcript, or portions thereof, confidential. The party designating a deposition transcript or portion of a deposition transcript as confidential shall provide written notice to all parties by listing the page and inclusive line numbers of the material to be kept confidential, and shall designate such pages to be "Confidential". In any deposition transcript in which any portion of the transcript has been designated confidential by any party, the court reporter, or the party holding the original transcript, shall imprint the word "Confidential" on the front page of the original of the deposition ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.