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Barbero v. Zurich American Insurance Co.

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

August 17, 2017

JOHN BARBERO, Plaintiff,
v.
ZURICH AMERICAN INSURANCE CO., Defendant.

          Margaret Behringer Maloney Maloney Law & Associates, PLLC Attorney for Plaintiff

          Keith M. Weddington N.C. Bar No. 14352 Parker Poe Adams & Bernstein LLP Erin Dougherty Foley (pro hac vice) Katherine F. Mendez (pro hac vice) Seyfarth Shaw LLP Attorneys for Defendant

          CONSENT PROTECTIVE ORDER

          DAVID S. CAYER UNITED STATES MAGISTRATE JUDGE

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, upon Joint Motion by the parties, with the consent of the parties, and it appearing that the discovery process in this action may involve the production of information that a party may contend is confidential and/or proprietary, and it further appearing that good cause exists for the entry of an order limiting the disclosure of such information;

         IT IS THEREFORE ORDERED that:

         1. “Confidential Information” as used herein means: personnel information of Plaintiff and other current or former employees of Defendant; Plaintiff's personal information, including medical, financial and tax records; and, all proprietary, business, financial or other commercially sensitive information, whether documentary or otherwise, designated as “confidential” and delivered, produced or disclosed by any party in this action, or by a third party, voluntarily or in response to an interrogatory, a request for production of documents, a deposition question, subpoena or otherwise. The designation of documents or information as “Confidential Information” shall not be conclusive for purposes of any substantive issues in this case.

         2. All documents produced or information provided or disclosed by any party in discovery in this action or by a third party as identified in paragraph 1 shall be treated as confidential and the use or disclosure of such documents or information shall be governed by the terms of this Order, provided that the party or third party producing or otherwise disclosing such documents or information designates in good faith such documents or information as “confidential” at the time of production or disclosure or as otherwise provided herein.

         3. Confidential Information, including copies or summaries thereof, shall be used only for the prosecution or defense of this action (including, but not limited to, any mediation, arbitration, or other settlement process, as well as appeals of this action) and shall not be used or employed for any other purpose whatsoever. Confidential Information shall not be disclosed or made available to anyone except:

         a. the Court;

         b. the parties to this action and officers, directors or employees of the parties who are actively participating in the prosecution or defense of this action;

         c. counsel for the parties to this action and employees or independent contractors of said counsel;

         d. experts or consultants specifically retained by the parties or their attorneys to assist them in the preparation of this case or to serve as expert witnesses at the trial of this action;

         e. third-party witnesses or potential witnesses whom counsel reasonably deem necessary for the preparation and trial of this action;

         f. court reporters engaged to record depositions, hearings or trials in this action; and g. mediators assigned to this case ...


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