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Richardson v. PCS Phosphate Co., Inc.

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

June 2, 2017

JAMES NORMAN RICHARDSON, Plaintiff,
v.
PCS PHOSPHATE COMPANY, INC. F/K/A ELF AQUITAINE, F/K/A TEXAS GULF AND CRAWFORD COMPANY D/B/A BROADSPIRE SERVICES, INC. Defendants.

          Attorney for Plaintiff Vernon Sumwalt (with permission)

          Attorney for Broadspire Jon Berkelhammer (with permission)

          Attorney for PCS S. McKinley Gray, III

          CONFIDENTIALITY AGREEMENT AND CONSENT PROTECTIVE ORDER

          Graham C. Mullen, United States District Judge

         The parties to this action, Plaintiff James Norman Richardson ("Plaintiff"), Defendant PCS Phosphate Company, Inc. ("PCS"), and Defendant Broadspire Services, Inc. ("Broadspire") (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. 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.

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

(1) "Plaintiff" shall mean James Norman Richardson 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) "PCS" shall mean Defendant PCS Phosphate Company 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) "Broadspire" shall mean Broadspire Services, Inc. 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.
(4) “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 personal information.

         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 ...


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