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Hines v. Northern Engraving Corp.

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

April 11, 2017

SCOTT HINES, Plaintiff
v.
NORTHERN ENGRAVING CORPORATION, Defendant.

          Paul E. Culpepper NC Bar No. 19883 Timothy D. Swanson NC Bar No. 35598 Counsel for Plaintiff

          Frederick T. Smith NC Bar No. 45229 SEYFARTH SHAW LLP Ada W. Dolph Counsel for Defendant

          CONSENT PROTECTIVE ORDER

          David C. Keesler United States Magistrate Judge

         To facilitate the prompt resolution of disputes over confidentiality and adequately protect material entitled to be kept confidential, the parties in the above-captioned matter, by and through their respective counsel, and pursuant Rule 26(c) of the Federal Rules of Civil Procedure, the parties hereby stipulate and agree to the terms of this Consent Protective Order (“Order”) as follows:

         1. Scope.

         This Order shall apply to information, testimony, documents and things provided by the parties in the above-captioned matter that contain: information protected from disclosure by statute; personal information (such as Social Security numbers); trade secrets; sensitive security data; or information in any format that the producing party believes in good faith constitutes or reveals any confidential, proprietary, commercially sensitive, or otherwise non-public business, technical, financial, or employee personnel information, or information protected by third-party privacy rights provided that any such information is generally unavailable to others, not readily determinable from other sources, and reasonably likely to lead to competitive injury, invasion of privacy, or annoyance or oppression if disclosed to persons other than as provided herein.

         2. Non-disclosure of Stamped Confidential Documents.

         No stamped confidential document may be disclosed to any person except as provided in paragraph 3 below. A “stamped confidential document” means any document that bears the legend “CONFIDENTIAL.” For purposes of this Order, the term “document” shall have the meaning assigned to that term in Rule 34(a).

         3. Permissible Disclosures.

         Stamped confidential documents and information may be disclosed to:

(a) counsel for the parties in this action who are actively engaged in the conduct of this litigation, including counsel's legal and clerical assistants;
(b) a party, or an officer, director, or employee of a corporate party deemed necessary by counsel for that party to aid in the prosecution, defense, or settlement of this action;
(c) this Court or any other court exercising appellate jurisdiction with respect to the determinations of this Court, court officials, employees, and stenographers transcribing testimony or ...

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