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Moving Simplified, Inc. v. Estes Express Lines, Inc.

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

January 2, 2018

MOVING SIMPLIFIED, INC., Plaintiff,
v.
ESTES EXPRESS LINES, INC. d/b/a ESTES SUREMOVE, Defendant.

          JOHN F. HANZEL COUNSEL FOR PLAINTIFF MOVING SIMPLIFIED, INC.

          ERIC P. STEVENS, ANDREW H. ERTESCHIK, JOHN M. DURNOVICH COUNSEL FOR DEFENDANT ESTES EXPRESS LINES, INC.

          CONSENT PROTECTIVE ORDER

          Graham C. Mullen United States District Judge

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, and with the consent of the parties to this action, IT IS HEREBY ORDERED THAT:

         1. Any party hereto, or any third-party, producing, or providing documents, testimony or information in response to discovery or any other formal or informal request for information or documents, may designate as Confidential Material all or any part thereof containing sensitive financial, trade secret, marketing, customer, research, development, proprietary, other commercial information, or other sensitive information the producing party wishes to protect under this Consent Protective Order. All such responses and the information contained in them are referred to herein as “Confidential Material.”

         2. The parties shall make the designation “Confidential Material” in the following manner:

a. In the case of documents or other written materials, by affixing to the first page of each such document the word “CONFIDENTIAL” by label, stamp or other method which will make that word reasonably conspicuous;
b. In the case of electronic media, by affixing to the CD, video tape, audio tape, or other magnetic media, or the case for said material the word “CONFIDENTIAL” by label, stamp, or other method which will make that word reasonably conspicuous;
c. In the case of large numbers of documents or bulk documents, by producing them for inspection by “Qualified Persons” as identified in Paragraph 4 of this Order with a statement that the information contained in the documents is confidential, and then by specifically labeling, stamping or marking as confidential only those documents which counsel for the inspecting party requests copies; and
d. During depositions, by either indicating on the record at the deposition the specific testimony which contains Confidential Information that is to be made subject to the provisions of this Order or by designating, in writing, within 30 days following receipt of the transcript of the deposition, of the specific pages and lines of the transcript that are to be designated Confidential. Each producing party shall attach a copy of such written designation to the face of the transcript and each copy thereof in its possession, custody or control.

         3. Any material thus designated as Confidential Material shall be revealed only to and used only by “Qualified Persons” as provided in Paragraph 4 of this Order and only in connection with the litigation of this case or for purposes of settlement discussions. Such Confidential Material shall not: (1) be used for the purpose of competing in business with the party providing the Confidential Material; (2) used for any other commercial or business purpose; (3) be disclosed by such Qualified Persons to anyone except other Qualified Persons; or (4) be used in any other civil action or legal proceeding without the written agreement of the party who produced the material or without further order of this Court.

         4. As used herein, “Qualified Persons” means:

a. This Court, including its staff and any jury selected in this case, under such safeguards as are provided in this Order or as are required by this Court in the event any Confidential Material is to be used or introduced at trial;
b. Present and subsequent in-house and outside counsel for the parties to this action, together with their paralegals and clerical employees actually ...

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