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Smith v. Flanders Holdings, LLC

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

May 10, 2017

HARRY L. SMITH, JR., Plaintiff,
v.
FLANDERS HOLDINGS, LLC, Defendant.

          Kevin M. Ceglowski Attorney for Plaintiff Harry L. Smith, Jr.

          S. McKinley Gray, III Attorneys for Defendant Flanders Holdings, Inc.

          CONSENT PROTECTIVE ORDER

          Louise W. Flanagan United States District Judge

         CONFIDENTIALITY AGREEMENT AND CONSENT PROTECTIVE ORDER

         The parties to this action, Plaintiff Harry L. Smith, Jr. ("Plaintiff), and Defendant Flanders Holdings, LLC ("Defendant") (collectively, "Parties") hereby consent and request that the Court enter a Protective Order with respect to the documents and information to be provided by any of the parties in response to interrogatories, requests to produce documents, and/or in depositions which may include confidential, proprietary or trade secret information relating to or referencing the underlying "Equity Buy Out and Board of Directors Resignation and Agreement, " the Parties' intentions respecting the same, and/or the sale of any business entity, or a portion thereof, involving the Parties, including the Parties' intentions with respect to such sale. In particular, the Parties seek to protect as confidential information referencing or potentially referencing trade secrets, proprietary, financial, operational data, business plans, competitive analyses, personnel files, or other business information and personal information of both Parties.

         As used herein, the following terms shall have these specified meanings:

         (1) "Plaintiff shall mean Harry L. Smith, Jr. and/or his employees, officers, agents or representatives as well as persons acting or purporting to act on their behalf for any purpose relevant to this matter.

         (2) "Defendant" shall mean Defendant Flanders Holdings, LLC and/or its employees, officers, agents or representatives as well as persons acting or purporting to act on their behalf for any purpose relevant to this matter.

         (3) "Confidential Information" shall mean information referencing or potentially referencing trade secrets, proprietary, financial, operational data, business plans, competitive analyses, personnel files, or other business information and/or personal information, including without limitation emails, documents, records, and/or communications contained on Defendant's computer information and email system.

         Pursuant to the Parties' request, and in accordance with the agreement of the Parties, IT IS HEREBY ORDERED:

         1. Counsel for any party may designate Confidential Information as "CONFIDENTIAL" if counsel determines, in good faith, that such designation is necessary to protect the interests of the client.

         2. Unless otherwise ordered by the Court, or otherwise provided herein, Confidential Information will be held and used solely by the person receiving the information solely for use in connection with the above-captioned action.

         3. Confidential Information designated as CONFIDENTIAL shall not be disclosed or disseminated to anyone, except:

         A. A Party, counsel for any Party, and the employees of such counsel to whom it is necessary that the information be ...


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