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Grasso v. Wells Fargo, N.A.

United States District Court, W.D. North Carolina, Charlotte Division

March 29, 2017

CHERYL GRASSO, Plaintiff,
v.
WELLS FARGO, N.A., Defendant.

          AGREED PROTECTIVE ORDER

          Frank D. Whitney, Chief United States District Judge

         THIS MATTER is before the Court on the parties' consent Motion for a Protective Order (Doc. No. 13). For the reasons stated therein, the Court GRANTS the motion and orders as follows:

         The parties hereto, Plaintiff CHERYL GRASSO and Defendant WELLS FARGO BANK, N.A., having consented through their respective counsel for the entry of this Agreed Protective Order, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, in order to protect the confidentiality of certain information and to facilitate discovery, IT IS HEREBY ORDERED THAT:

         1. This Agreed Protective Order shall remain in effect for the duration of this action, unless otherwise ordered by the Court or agreed by the parties.

         2. The purpose of this Agreed Protective Order is to protect against the unnecessary disclosure of confidential information. Information and documents protected by this Agreed Protective Order shall include:

a. All information and documents produced by Defendant in this action that refer to, reflect upon, or relate to any applicant for employment or any current or former employee of Defendant other than Plaintiff, including, but not limited to, documents contained in such employees' personnel and medical files and Defendant's Human Resources Department files;
b. Defendant's trade secrets or other confidential proprietary technical, business, or financial information that is not generally known to the public;
c. Plaintiff's medical file and any other medical information pertaining to Plaintiff;
d. Any other documents or testimony that a party in good faith designates as “confidential.”

         The information and documents protected by this Agreed Protective Order shall be referred to as “Confidential Materials.” The restrictions contained herein regarding disclosure of Confidential Materials also apply with equal force to any copies, excerpts, analyses, or summaries of such materials or the information contained therein, as well as to any pleadings, memoranda, briefs, exhibits, transcripts, or other documents that may be prepared in connection with this action that contain or refer to the Confidential Materials or information contained therein.

         3. “Disclosure” or “to disclose” shall mean to divulge, reveal, describe, summarize, paraphrase, quote, transmit, or otherwise provide or communicate to any person or entity the Confidential Materials, whether pursuant to request, interrogatory, process, or otherwise, and whether in accordance with the Federal Rules of Civil Procedure or otherwise.

         4. Confidential Materials shall be used solely for the purpose of this action, shall not be used for any other business, competitive or other purpose, and shall not be disclosed to any other person or entity other than:

a. The parties in this action;
b. Counsel for the parties in this action, including employees of such counsel to the extent necessary to render ...

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