United States District Court, W.D. North Carolina, Charlotte Division
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
C. Keesler, United States Magistrate Judge.
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
Parties therefore stipulate that:
“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.
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.
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
(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
(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 ...