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Liberty Mutual Insurance Co. v. Oak City Contracting, LLC

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

October 30, 2017

LIBERTY MUTUAL INSURANCE COMPANY, Plaintiff,
v.
OAK CITY CONTRACTING, LLC, Defendant.

          Paul E. Davis Conner Gwyn Schenck PLLC Attorneys for Liberty Mutual Insurance Company.

          Albert L. Chollet, III Erica Marie Del Aguila Watt, Tieder, Hoffar & Fitzgerald, L.L.P. Attorneys for Liberty Mutual Insurance Company.

          William J. Wolf N. C. State Bar No. 14357 Bugg & Wolf, P.A. Attorneys for Oak City Contracting, LLC.

          STIPULATION AND CONSENT PROTECTIVE ORDER

          ROBERT T. NUMBERS, II UNITED STATES MAGISTRATE JUDGE.

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the parties to this action file this Stipulation and Consent Protective Order to establish a mechanism to facilitate the flow of information and discovery in connection with this litigation, while protecting information that the parties believe, in good faith, does or may constitute confidential and/or proprietary information.

         It is therefore AGREED and ORDERED as follows:

         1. As used in this Order, “Confidential Material” means information designated as confidential by the producing party which falls within one or more of the following categories: (a) information prohibited from disclosure by statute; (b) information that reveals trade secrets; (c) research, technical, commercial or financial information that the party has maintained as confidential; (d) medical information concerning any individual; (e) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or (f) personnel or employment records about a person who is not a party to the case. Information or documents that are available to the public may not be designated as Confidential Material.

         2. Confidential Material produced or procured during discovery or during trial preparation for this case, and copies thereof, and the information contained therein, shall be made available to and inspected by the following persons only:

a. The parties, their officers, employees, and agents who are assisting in prosecuting or defending this action;
b. Counsel for the parties in this action, and their assistants, paralegals or other persons associated with counsel, whose assistance is required by said attorneys in the defense or prosecution of this litigation;
c. In-house counsel, if any, for the parties and their assistants, paralegals or other persons associated with in-house counsel, whose assistance is required by said attorneys in the defense or prosecution of this litigation;
d. Expert witnesses and consultants, and their employees, who are directly employed or retained in connection with this action by counsel for the parties, to the extent that such disclosure is necessary for the prosecution or defense of this case;
e. Other witnesses or deponents, and their counsel, during the course of or in preparation for deposition or testimony in this action as necessary for the prosecution or defense of this lit igation;
f. The Court and court personnel, including court reporters at proceedings in this action and ...

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