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Brown v. Frost-Arnett Co.

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

April 17, 2017

KENDALL BROWN, Plaintiff
v.
FROST-ARNETT COMPANY Defendant.

          BEDARD LAW GROUP, P.C. Jonathan K. Aust Counsel for Defendant

          MAGINNIS LAW, PLLC Karl Gwaltney, Edward H. Maginnis Counsel for Plaintiff

          STIPULATED ORDER - CONFIDENTIALITY AGREEMENT

          David C. Keesler United States Magistrate Judge

         The parties have advised the Court that they anticipate discovery and production of documents which may be the proper subject of non-disclosure under FRCP 26(c)(1)(G). In order to assist in the timely completion of discovery, the Court enters this Order governing the procedure for seeking the protections under FRCP 26(c)(1)(G).

         1. Confidentiality as a Basis of Non-Disclosure.

         Having provided the parties a mechanism for the protection of documents of information of a confidential nature, the parties may not assert the confidential nature or trade secret status of documents as a basis of non-disclosures except as provided in this order.

         2. Designation of Confidentiality.

         A party responding to requests for production or interrogatories may designate the responsive information to that discovery as confidential (hereafter referred to as “information designated as confidential”). That party shall make the designation by producing the information and affixing a stamp conspicuously designating the information as “CONFIDENTIAL.” .

         3. Protection of Information Designated as Confidential.

         Any information designated as confidential shall be protected as confidential under the terms of this Order until such time as 1) the Court rules on the designation pursuant to a motion by designating party, 2) the designating party waives the objection expressly or by failure to file a timely motion for a protective order, 3) the documents are submitted to the Court in connection with a dispositive motion, or 4) the documents are submitted at trial of this matter.

         If any information which is protected as confidential is submitted in connection with a dispositive motion or at trial pursuant to this Order, the information ceases to be protected as confidential, but any party may move to seal the Court's record and proceedings under the applicable law as provided below.

         Any information contained in, or derived from any information designated as confidential (including but not limited to, all deposition testimony that refers, reflects or otherwise discusses any information designated confidential hereunder) may not be disclosed other than in accordance with this Order.

         Any information which is protected as confidential may not be used outside this case and may only be used in this litigation. Information ...


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