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Norkus v. Outback Steakhouse of Florida, LLC

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

May 12, 2017

REBECCA F. NORKUS, Plaintiff,
v.
OUTBACK STEAKIIOUSE OF FLORIDA, LLC, Defendant.

          CONSENT PROTECTIVE ORDER (AS MODIFIED)

          James E. Gates United States Magistrate Judge

         THIS CAUSE came on to be heard upon the joint motion of Plaintiff Rebecca Norkus ("Plaintiff), and Defendant Outback Steakhouse of Florida, LLC ("Defendant"); and it appearing to the Court that discovery and the trial in this action may involve the production and disclosure of confidential, proprietary, or sensitive information requiring protection against unrestricted disclosure or use;

         THEREFORE, IT IS HEREBY STIPULATED, AGREED AND ORDERED that pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the following confidentiality provisions shall govern all information and documents disclosed in discovery in this action:

         1. Certain information and documents to be produced by Plaintiff and Defendant during discovery in this litigation may contain confidential medical records, financial records, trade secrets or other proprietary, confidential research, development, commercial information, and other documents that should be considered confidential and protected from unreasonable disclosure pursuant to Rule 26(c) of the Federal Rules of Civil Procedure.

         2. The information and documents to be considered as confidential and disclosed only in accordance with the terms of this Consent Protective Order ("this Order") shall include, without limitation, all documents or information whether in hard copy or electronic form designated in accordance with the terms of this Order and supplied in response to the demands or requests of either party, formal or informal, regardless of whether said information is produced or disclosed by a party or by any affiliated person or entity, or formerly affiliated person or entity.

         3. All information designated "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY" in accordance with the terms of this Order and disclosed in discovery in this action shall be used solely for purposes of prosecuting or defending this litigation and shall not be used for any other purpose.

         4. "Discovery Material" shall mean and include any document (whether in hard copy or computer readable form), thing, deposition testimony, interrogatory answers, responses to requests for admissions and/or production, or other information provided in discovery in this action. Any party may. in good faith, designate Discovery Material as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY." Discovery Material designated "CONFIDENTIAL" shall contain non-public proprietary or medical information, whether personal or business-related; information protected from disclosure by contractual obligations with third parties; or information protected from disclosure by law. Certain limited types of "CONFIDENTIAL" information may be alternatively designated, as defined and detailed below, as "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY." The "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY" designation shall be reserved for confidential information that constitutes, reflects, or concerns trade secrets, know-how or proprietary data, business, financial, or commercial information, the disclosure of which is likely to cause harm to the competitive position of the party making the confidential designations of Discovery Material. "CONFIDENTIAL" or ••HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY" information, as used in this Order, shall refer to any information so designated.

         5. All information designated "CONFIDENTIAL" shall be maintained in confidence by the parties to whom such information is produced or given, shall be used solely for the purposes of this litigation, and shall not be disclosed to any person except:

(a) The Court (including court reporters, stenographic reporters and videographers, and court personnel);
(b) The attorneys of record, their partners, employees, contractors, and associates of outside counsel (collectively hereafter referred to as "Outside Counsel");
(c) The parties, including officers and employees of Defendant in this action; provided, that such officers or employees shall receive such "CONFIDENTIAL" information solely on a "need to know" basis for purposes of prosecuting or defending this litigation and for no other purposes;
(d) Subject to the terms of paragraph 13 below, experts and their staff and litigation support personnel and their staff retained by Outside Counsel in this litigation; and
(e) Any mediator and/or arbitrator selected with the consent of all parties or by the Court;
(f) Any other person as to whom the producing party agrees in writing prior to such disclosure.

         6. All information designated as "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY" shall be maintained in confidence for use by the attorneys of the parties, shall be used solely for the purposes of this litigation, and shall not be disclosed to any person except those ...


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