Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Suarez v. Camden Property Trust

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

December 18, 2017

JORGE SUAREZ, Plaintiff,
v.
CAMDEN PROPERTY TRUST, CAMDEN DEVELOPMENT, INC., and CSP COMMUNITY OWNER, LP f/k/a CSP COMMUNITY OWNER, LLC, d/b/a CAMDEN WESTWOOD, Defendants.

          Edward H. Maginnis Karl S. Gwaltney MAGINNIS LAW, PLLC, Scott C. Harris Patrick M. Wallace Attorneys for Plaintiff

          Kearns Davis N.C. D.J. O'Brien Attorneys for Defendants

          CONSENT PROTECTIVE ORDER

          Robert B. Jones, Jr. United States Magistrate Judge

         WHEREAS, there is good cause, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, for the entry of a protective order limiting disclosure of documents and information generated during discovery in this action, it is hereby ORDERED:

         1. Scope of Order.

         This Order governs the handling and disclosure of all materials produced, given, exchanged, or filed herein by any party or witness (each a "Producing Party") during discovery and other proceedings in this action (which includes but is not limited to all claims against all parties, including third party claims, and mediation, arbitration, or other alternative dispute resolution process, settlement proceedings, and/or appeals) (the "Action") designated as "Confidential Information." 2. Agreement on Use of Confidential Information. All Confidential Information, as defined and designated in accordance with this Order, shall be used solely in the prosecution or defense of this Action, as defined above, and shall not be used or disclosed by any person for any other purpose.

         3. "Document."

         When used in this Order, the term "document" means all writings, drawings, graphs, charts, recordings, computer disks and tapes, audiotapes, videotapes, and any other documents as defined in Rule 34 of the Federal Rules of Civil Procedure.

         4. "Material."

         When used in this Order, the term "material" means any document, any answer to any interrogatory or other discovery request in this action, any portion of any deposition (including deposition exhibits) in this action, and any other information produced, given, or filed in this action.

         5. "Confidential Information."

         When used in this Order, the term "Confidential Information" means a trade secret or other confidential or proprietary information including, but not limited to confidential financial records and data, confidential business records and data, confidential business policies and procedures, and any information that would place a Producing Party at a competitive disadvantage in the event such information were released to competitors or to the general public. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case.

         6. Designation of Confidential Material.

         A Producing Party may designate material produced in the course of discovery as "Confidential Information." The production or disclosure pursuant to the terms of this Order of Confidential Information by a person shall not waive or prejudice the right of that person to object to the production or admissibility of documents or information in this or any other action. The Designating Party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify so that other portions of the documents, items, or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate, or routinized designations are prohibited. Any party who produces Confidential Information as defined in this Order or who designates material as Confidential Information as set forth in this Paragraph shall be referred to as the "Designating Party."

         If it comes to the Designating Party's attention that information or items that it designated for protection do not qualify for protection, that Designating Party must promptly notify all other ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.