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Evans v. Village Green Care Center, Ltd.

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

May 18, 2018

JACQUELINE EVANS, Plaintiff,
v.
VILLAGE GREEN CARE CENTER, LTD; VILLAGE GREEN REAL ESTATE AND DEVELOPMENT LLC; VILLAGE GREEN REHABILITATION. Defendants.

          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

         THIS 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.

         THE COURT, having considered the Motion and other appropriate matters of record, hereby GRANTS the Motion.

         Pursuant 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:

         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 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 "Confidential Information."

         2. Agreement on Use of Confidential Information.

         AH 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, 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.

         6. Designation of ...


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