United States District Court, E.D. North Carolina, Western Division
Patricia W. Goodson, Esq., Jessica Thaller-Moran, Esq., Sarah
M. Saint, Esq. BROOKS, PIERCE, McLENDON, HUMPHREY &
LEONARD, L.L.P. Attorneys for Defendants
Jacqueline M. Evans, pro se Attorneys for Plaintiff
CONFIDENTIALITY AND PROTECTIVE ORDER
MATTER is before the Court upon the parties' Joint Motion
for Confidentiality and Protective Order, seeking a
protective order to facilitate the discovery and disclosure
of confidential business, financial, personnel, and personal
information in this action.
COURT, having considered the Motion and other appropriate
matters of record, hereby GRANTS the Motion.
to Rule 26(c)(1) of the Federal Rules of Civil Procedure and
upon agreement of the parties, and deeming it just and proper
to do so, it is hereby ORDERED that:
Scope of Order.
Order governs the handling and disclosure of all materials
produced, given, exchanged, or filed herein by any party or
witness 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) designated as
Agreement on Use of Confidential Information.
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
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
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.
used in this Order, the term "Confidential
Information" means a trade secret or other confidential
or proprietary information including, but not limited to,
medical records, personnel and payroll records and files,
financial records and data, business records and data,
business policies and procedures, any information that would
place the party producing such information at a competitive
disadvantage in the event such information were released to
competitors or to the general public, and any other
information which shall be designated as confidential
pursuant to this Protective Order.
Designation of ...