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Faison v. Harris Teeter, LLC

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

October 18, 2017

LAKEYDA FAISON, Plaintiff,
v.
HARRIS TEETER, LLC, Defendant.

          Finlon Law PLLC Kristen E. Finlon, N.C. Attorney for Plaintiff

          Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Regina W. Calabro Brodie Erwin Attorneys for Defendant

          CONSENT PROTECTIVE ORDER

          David C. Keesler, United States Magistrate Judge.

         This matter is before the Court upon joint stipulation of the Parties, Lakeyda Faison (hereafter “Plaintiff”) and Defendant Harris Teeter, LLC (hereafter “Defendant”), for a protective order. Pursuant to the consent of the parties, this Protective Order governing certain records, documents and information should be entered in this matter for the reason that one or both parties assert that this information is confidential, sensitive and/or proprietary.

         The Parties therefore stipulate that:

         1. “Confidential Material” as used herein refers to any personnel or business records, documents, or any other confidential or personnel-related information, however described, which may include business records, tax records, medical documents, and other confidential agreements or materials the parties may have. Copies of any such information that a party contends is confidential may be stamped “CONFIDENTIAL” and/or be identified as “CONFIDENTIAL” or subject to a protective order in response to discovery requests. Such information shall be designated as CONFIDENTIAL only upon a good faith belief that the information falls within this definition.

         2. All Confidential Material in whatever form subject to this Protective Order, shall be used by the receiving party only in connection with the above-referenced action, Faison v. Harris Teeter, LLC, pending in the United States District Court for the Western District of North Carolina, and shall not be used in connection with any other lawsuit or for any other purpose whatsoever.

         3. All information subject to this Protective Order shall be revealed only as follows:

(a) To the Court;
(b) To attorneys of record for the parties in this litigation, in-house counsel for those parties which are legal entities, insurance adjusters assigned to this case by an insurance company that may be obligated in whole or in part to pay for the defense, settlement and/or judgment in this case, and employees or independent contractors (i.e. contract lawyers, document imaging and electronic discovery companies, computer forensic companies, litigation support companies, and others) of such attorneys of record and/or in-house counsel to whom it is necessary that the Confidential Material be shown for purposes of this litigation;
(c) To each party to this case or, where the party is a legal entity, such party's representatives;
(d) To court reporters and/or videographers retained for use in this matter;
(e) To any deponent (solely for the purposes of his/her deposition or preparation for that deposition) if such information is reasonably likely to be relevant to the deposition;
(f) To any witness if such information is reasonably likely to be relevant to that witness's knowledge or subject matter of testimony, but the witness shall not be able ...

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