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Moore v. Innovative Systems, LLC

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

June 12, 2017

PAUL B. MOORE, JR. Plaintiff,
v.
INNOVATIVE SYSTEMS, LLC, Defendant.

          WYRICK ROBBINS YATES & PONTON LLP Kyle R. Still, T. Cullen Stafford COUNSEL FOR DEFENDANT

          BARRETT LAW OFFICES, PLLC William P. Barrett, Joshua M. Krasner COUNSEL FOR PLAINTIFF

          CONSENT CONFIDENTIALITY AND PROTECTIVE ORDER (AS MODIFIED)

          James E. Gates United States Magistrate Judge

         Pursuant to Fed.R.Civ.P. 26(c) and in order to protect the parties from disclosure of proprietary or confidential information, the undersigned hereby stipulate and agree to this Consent Confidentiality and Protective Order (the "Stipulation") and agree that a protective order may be entered, as set forth herein.

         In the course of this action, Plaintiff may request production of documents and information related to Defendant's current or former employees and/or Defendant's projected sales, and Defendant may use such documents and information in its defense. Portions of such documents and information are protected from disclosure absent a lawfully issued judicial order or subpoena. The parties have an interest in limiting disclosure of the records and information for any purposes other than the litigation process of this case. The parties shall be permitted to designate as confidential only documents or information which they believe in good faith to be or contain information within the scope of Rule 26(c) of the Federal Rules of Civil Procedure. Moreover, the parties shall be obligated to make specific designations to the extent reasonably possible and to avoid overbroad designations.

         IT IS HEREBY ORDERED that:

         1. Documents produced and testimony given in this case shall be used solely for purposes of the preparation and trial of this litigation, mediation and any related appellate proceeding and for no other purpose.

         2. Each party may identify and designate documents and things produced by it, and answers to interrogatories and responses to other discovery demands as "Confidential" to the extent that such party in good faith believes such documents, things, answers and responses contain confidential information, including, but not limited to, trade secrets, confidential or proprietary business plans, forecasts or data; confidential or proprietary financial plans, forecasts or data; confidential or proprietary operational plans, forecasts or data; or sensitive commercial, financial, customer, or personal information; or if it is of a type deemed privileged or confidential by any state or federal statute or regulation. This Order does not apply to documents or things which may be covered by the attorney work product privilege or the attorney-client communication privilege. Such material shall be handled by the parties in accordance with applicable law. Documents that are designated by the parties as Confidential may be produced pursuant to this Stipulation for Protective Order. All such documents shall be marked as "Confidential."

         3. Material deemed or designated "Confidential" and any material obtained or derived therefrom (collectively, "Confidential Information") shall be inspected or used solely by:

(a) counsel for the parties to this litigation and persons in their employ who are assisting in the conduct of this litigation, including outside contractors;
(b) the parties to this litigation and the officers, directors, partners, principals and employees, whether past, present, or future, of such parties who are involved in the preparation of this action (collectively, "Party Representatives");
(c) experts retained to testify at trial, or consultants retained or engaged by a party in preparation for trial (collectively, "Consultants"), each of whom has signed an undertaking in the form of Exhibit A, as provided in paragraph 5 below;
(d) persons who prepared or who have previously received particular documents, provided that the inspection or use of Confidential Information by such persons is limited only to those documents prepared or previously received;
(e) insurers that provide or are requested to provide coverage for the claims asserted in this case, and their counsel;
(f) judicial officers and personnel (including stenographic reporters); and
(g) any other person, including any witnesses in this matter, who the parties jointly authorize to see Confidential Information, provided that each such person shall sign an undertaking in the form of ...

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