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Ragan v. Mecklenburg EMS Agency

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

January 9, 2018

TARA RAGAN, Plaintiff,
v.
MECKLENBURG EMS AGENCY d/b/a MEDIC Defendant.

          Margaret Behringer Maloney N.C. State Bar No. 13253 Attorney for Plaintiff

          J. Michael Honeycutt N.C. State Bar No. 33437 Meredith W. Norvell N.C. State Bar No. 51060 Adam M. Bridgers N.C. State Bar No. 39543 FISHER & PHILLIPS LLP Attorneys For Defendant

          CONSENT PROTECTIVE ORDER

          David C. Keesler United States Magistrate Judge

         This lawsuit involves claims by Tara Ragan (hereinafter "Plaintiff' or "Ragan") for discrimination and retaliation under Title VII on the basis of sex and also wrongful discharge in violation of North Carolina public policy against Defendant Mecklenburg EMS Agency d/b/a Medic (hereafter “Medic” or “Defendant”). Defendant has denied any liability to Plaintiff and has asserted a number of defenses.

         The parties anticipate that certain information relevant to the Plaintiff's claims and Defendant's defenses in this lawsuit is confidential, sensitive, and/or proprietary personnel and/or business information that should be protected pursuant to a Court Order. For this reason, the parties desire to ensure that certain information provided, released, exchanged, or reviewed during discovery is not used or disclosed improperly and to ensure that confidential, sensitive and proprietary information is sufficiently protected. Because of these concerns, the parties agree to the following provisions regarding the discovery of information, documents, items, and other materials during the discovery of this lawsuit and continuing through trial.

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, and upon agreement of counsel, and deeming it just and proper to do so, the Court enters the following ORDER:

         1. This Order governs the handling and disclosure of all materials produced, given or filed herein by the parties and designated as "CONFIDENTIAL."

         2. Any party producing documents, material or other information (collectively "Information") in this litigation which that party reasonably believes is confidential, sensitive and/or proprietary and the public disclosure of which would be harmful to that party, may designate such Information, or any part thereof, as confidential (hereinafter "Confidential Information"). Any discovery material designated Confidential Information shall be clearly marked by the producing party with the word "CONFIDENTIAL" on each page or object so designated.

         3. "Confidential Information" as used herein includes, but is not necessarily limited to:

a. All information produced regarding Plaintiff or any other current or former employee of either party, including, but not limited to, information regarding investigations, complaints and discipline related to any such employee(s), any medical information relating to such employee(s), information containing social security numbers, dates of birth, banking information or similar sensitive information of such employee(s), records of such employee(s)' payroll, overtime, wages, or hours worked and any other sensitive information regarding the employee(s);
b. All proprietary, financial or other sensitive information, which is not generally accessible to the public, is entitled to an expectation of privacy, and is otherwise treated by a party as confidential;
c. Any documents, records or information which relate to any medical treatment of Plaintiff;
d. Any other information the parties deem "Confidential Information" as discovery progresses in this matter.

         4. Should a party object to the designation of any material as "Confidential Information, " that party may apply to the Court for a ruling on the propriety or legitimacy of the designation. Until the Court enters an Order, if any, changing the designation of the material, it ...


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