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Toland v. Suntrust Bank

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

October 13, 2017

RONALD TOLAND, JR., Plaintiff,
v.
SUNTRUST BANK, Defendant.

          Elizabeth C. Stone, Williams Mullen, Attorney for Defendant SunTrust Bank

          Suzanne Begnoche, Suzanne Begnoche, Attorney at Law, Attorney for Plaintiff Ronald Toland, Jr.

          CONSENT PROTECTIVE ORDER

          THE HONORABLE TERIJPNCE W. BOYLE, UNITED STATES DISTRICT JUDGE.

         THIS CAUSE came on to be heard upon the joint motion of Plaintiff Ronald Toland, Jr. ("Plaintiff) and Defendant SunTrust Bank ("Defendant") and it appearing to the Court that discovery and the trial in this action may involve the production and disclosure of confidential, proprietary, personal and/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 personal, medical, or financial information, trade secrets or other proprietary, confidential research, development, or commercial information that should be considered confidential and protected from unreasonable disclosure pursuant to Fed.R.Civ.P. 26(c).
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, to include deposition testimony, 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 or disclosed solely for purposes of prosecuting or defending this litigation and shall not be used or disclosed for any other reason or purpose whatsoever, and such use or disclosure may be made only as provided herein.
4. "Discovery Material" shall mean and include any document, or portions thereof, (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. For purposes of this proceeding, parties and nonparties may designate material as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL ATTORNEYS EYES ONLY." Such Designation shall constitute a representation to the Court that counsel believes in good faith that the information (1) constitutes information subject to protection under Rule 26(c) and (2) that there is good cause for the same to be protected from public disclosure. Discovery Material designated "CONFIDENTIAL" shall mean and include all information subject to protection under Fed.R.Civ.P. 26, whether personal or business-related. 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, and 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 and other people whose involvement is required by the litigation process (including court reporters, stenographic reporters and videographers, and court personnel);
b. The attorneys of record, their partners, employees, and associates of outside counsel (collectively hereafter referred to as "Outside Counsel");
c. Plaintiff, officers or employees of Defendant, and necessary non-party witnesses provided, that such parties 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, contractors, and litigation support personnel and their staff retained by Outside Counsel in this litigation;
e. Individuals, including but not limited to the former employees, agents, consultants, or independent contractors of the parties, who authored or prior to the commencement of this litigation ...

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