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Mazzariello v. Atlantic Coast Waterproofing, Inc.

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

December 14, 2017

ARCANGELA MAZZARIELLO, Plaintiff,
v.
ATLANTIC COAST WATERPROOFING, INC., and FEDERICO JARAMILLO, individually, Defendants.

          CONSENT PROTECTIVE ORDER

         The Parties have agreed to the following, and for good cause shown, IT IS HEREBY ORDERED as follows:

         1. In accordance with the provisions set forth below, the Court intends that confidential information and documents produced, obtained, or exchanged in the course of this action shall be used by the party to whom such documents are produced, obtained, or exchanged solely for the purpose of this lawsuit and for no other purposes.

         2. Any documents produced or exchanged between Parties, and any information contained in discovery, including but not limited to produced documents, deposition testimony, and deposition exhibits, which a party believes is protected from disclosure under governing law, may be designated as “Confidential.” All documents and information so designated and all copies thereof (hereinafter referred to collectively as “Confidential Information”), shall be treated as confidential and shall not be disclosed except as provided in this Order; provided, however, that counsel for the party designating information as Confidential may, in writing and without Court approval, agree to release any Confidential Information from the requirements of this Order; and provided further that nothing in this Order shall prevent any party from challenging the designation of any document as Confidential.

         3. Any party may designate a document as Confidential pursuant to the terms of this Order by affixing to the first page thereof a stand with the legend “CONFIDENTIAL” or may, in the alternative, by written notice inform opposing counsel that the document is to be treated as Confidential Information. It is agreed by the parties that if a party wishes to maintain the confidentiality of a document designated as confidential in a brief or other court-filed document, then the party must follow the procedures set forth in paragraphs 9 and 10 of this Consent Protective Order. Furthermore, a party initially designating a document as Confidential does not obligate either party to file it under seal unless so required by this Court.

         4. Confidential Information shall be produced only to counsel of record in this action, all of whom is bound by the terms of this Order.

         5. Neither the Confidential Information nor its contents shall be disclosed to any other person without the agreement of the party designating information as Confidential, except that counsel may, without further agreement, disclose the Confidential Information or its contents to the following persons for use solely in connection with this action under the following conditions:

a. The Parties and their attorneys, legal assistants, and other employees of the Parties who have a need to handle the Confidential Information under normal office procedure;
b. Experts or consultants retained by the Parties with respect to this action;
c. Any person from whom testimony has been taken or is reasonably expected to be taken in this action (whether by deposition or at trial);
d. This Court and its staff; witnesses during hearings, depositions, or trial, and to the jury upon admission by the Court into evidence; and
e. Any court reporters present in their official capacity at any hearing, deposition or other proceeding in this action.

         6. Any person may also designate portions of a deposition as Confidential Information by notifying the other party in writing within twenty (20) days of receipt of the transcript of the portions that are designated Confidential. The entirety of all depositions shall be treated as Confidential during this twenty (20) day period.

         7. Confidential Information shall be used solely for the purpose of prosecution or defense of this action, and such documents may be used, consistent with the terms of this Order, in pretrial discovery and at the trial or preparation for trial and any appeals of this action.

         8. Producing or receiving materials or otherwise complying with the ...


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