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Toro v. New NGC, Inc.

United States District Court, W.D. North Carolina

May 24, 2017

HENRY WILLIAM QUEZADA TORO, Plaintiff,
v.
NEW NGC, INC., Defendant.

          Pearlynn G. Houck N.C. Fitz E. Barringer N.C. Robinson, Bradshaw & Hinson, P.A. Attorneys for Defendant New NGC, Inc.

          Kerry B. Everett Everett Law, PLLC Attorney for Plaintiff Henry William Quezada Toro.

          STIPULATION AND PROTECTIVE ORDER

          Graham C. Mullen, I United States District Judge.

         IT IS HEREBY STIPULATED BY THE PARTIES AND ORDERED BY THE COURT that this Stipulation and Protective Order (the “Order”), shall govern the use of all documents produced (either formally or informally), responses to interrogatories, requests for admission, deposition transcripts, and all other information, documents, objects, or things that have been or will be produced (herein all referred to as “Discovery”) by any party to this action (a “Producing Party”).

         1.. Certain information, documents, and things to be produced in this action may be trade secrets; confidential research, development, or commercial information; or other personally or competitively confidential information (hereinafter “Confidential Information”); and Discovery may be designated as Confidential Information, if, after carefully reviewing material to segregate non-confidential from confidential information, the Producing Party and its counsel conclude, in good faith, that good cause exists, within the meaning of subparagraph (c)(1) of Rule 26 of the Federal Rules of Civil Procedure, for the Discovery to be so designated, under the terms of this Order. All such designations are to be reasonably limited both in subject matter and in time.

         2.. Any Discovery (e.g., any document or portion of a transcript, whether an original or copy, including any exhibits, answers to interrogatories and other written discovery responses, as well as physical objects, recordings or things) that any party deems to contain Confidential Information as defined in Paragraph 1, shall be labeled by such party on each page of such document or on such physical object with the designation “Confidential.” In lieu of marking this notation on the originals of documents, the party may mark the copies that are produced. All Confidential Information not reduced to documentary, tangible or physical form, or which cannot be conveniently labeled, shall be so designated by informing the recipients in writing that the information constitutes Confidential Information.

         3.. Any party may designate those portions of the transcript of a deposition that refer to matters deemed confidential pursuant to Paragraph 1 as Confidential Information by indicating on the record at the deposition that the testimony contains or reflects Confidential Information or by notifying all parties in writing, within 21 days of receipt of the transcript, of the specific pages and lines of the transcript which are Confidential. In order to afford time for designations to be made, the entire transcript of each deposition shall be treated as Confidential Information for a period of 21 days after a full and complete transcription of such deposition is available to the designating party.

         4.. Confidential Information shall not be publicly disclosed by any person or entity with knowledge of this Order unless in accordance with the terms of this Order. Confidential Information may be used only for the prosecution or defense of the above-captioned action and not for any other pending or threatened litigation, or any other business or other purpose whatsoever. Except as permitted hereunder or by order of the Court, all Confidential Information shall be maintained by the other party(s) to which the Confidential Information is provided (the “Receiving Party”) and by its counsel in a fully confidential manner, shall be properly secured to prevent inadvertent disclosure of the Confidential Information, and shall not be given, shown, disclosed, disseminated or described, directly or indirectly, to any person(s) other than as permitted in Paragraph 5 hereof.

         5.. The following persons (hereinafter called “Qualified Persons”) shall be the only persons who may have access to Confidential Information:

(a) the named plaintiff(s) and defendant in this action, and counsel of record for the named plaintiff(s) and defendant;
(b) employees of such counsel of record;
(c) consultants or expert witnesses retained for the prosecution or defense of this action, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit A before being shown or given any Confidential Information;
(d) the original author, addresses, or recipients of ...

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