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Seitz v. U.S. National Whitewater Center, Inc.

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

May 24, 2018

JAMES SEITZ, ADMINISTRATOR OF THE ESTATE OF LAUREN E. SEITZ, DECEASED, Plaintiff,
v.
U.S. NATIONAL WHITEWATER CENTER, INC., RECREATION ENGINEERING AND PLANNING, INC., and LIQUID DESIGN, P.C. Defendants.

          John T. Daniel Edward G. Connette Essex Richards, PA, Jose Manuel Lopez, Admitted Pro Hac, Jonathan Scott Zweizig, Admitted Pro Hac, Attorneys for Plaintiff.

          Chip Holmes, N.C., John H. Beyer, N.C., Morgan H. Rogers, N.C., Parker Poe Adams & Bernstein LLP Attorneys for Defendant U.S. National Whitewater Center, Inc.

          Mark Kutny, Hamilton Stephens Steele & Martin, PLLC, Attorney for Liquid Design, P.C.

          Joseph Lawrence Nelson Dickie, McCamey & Chicote, P.C., Mary Barley-McBride, Admitted Pro Hac Dickie, McCamey & Chicote, P.C., Attorneys for Defendant Recreation Engineering and Planning, Inc.

          STIPULATION OF CONFIDENTIALITY AND PROTECTIVE ORDER

          David S. Cayer United States Magistrate Judge.

         1. The “Litigation” shall mean the above-captioned case, No. 3:18-CV-00044-MOC-DSC or as the pleadings are amended.

         2. “Discovery Materials” shall mean and include any document (whether in hard copy or electronic form), records, responses to discovery, whether documentary or oral, and other information provided, served, disclosed, filed, by or through a Party or any non-party person or entity through discovery in connection with this Litigation, whether before or after entry of this Order. All such documents are produced pursuant to legal obligations arising under the Federal Rules of Civil Procedure. Discovery Materials shall be used solely and exclusively for the purposes of prosecuting or defending this Litigation, and shall not be used by a Party for any other purposes. Notwithstanding any other provision herein, nothing shall prevent a Party from using Discovery Materials that were created by, or through no unlawful means or activities were sent or received by, that Party prior to or outside the context of this Litigation.

         3. The term “producing Party” shall mean any Party or non-party person or entity that provides, serves, files, or produces any nonpublic information in connection with this Litigation.

         4. Discovery Materials produced or disclosed in connection with the Litigation by a producing Party may be designated as confidential by the producing Party, to the extent that such Discovery Materials include non-public and highly sensitive commercial, banking, tax, financial, personal, employee, medical or proprietary information, or information that is required to be kept confidential due to preexisting legal or contractual obligations. Confidential Discovery Material may be designated confidential by marking or stamping the page or pages containing such information as “CONFIDENTIAL” or by designating any thumb drive, CD, DVD, or other storage device for electronically formatted discovery on said device.

         5. Discovery Materials designated as confidential shall be referred to herein as “Confidential Discovery Material.” The Parties further agree that reference to any categories or types of Discovery Material above is not intended to and shall not be construed as an admission that the Discovery Material is, or is not, relevant; admissible; reasonably calculated to lead to the discovery of admissible evidence; or subject to an applicable privilege, protection or immunity.

         6. Confidential Discovery Material shall be maintained in strict confidence by the Parties and others who receive such documents or information, and shall be used solely and exclusively for the purposes of prosecuting or defending this Litigation, and shall not be used for any other purposes. Confidential Discovery Material shall not be disclosed to any person except:

(a) The Court and persons assisting the Court in the Litigation process (including, but not limited to, Court personnel, court reporters, stenographic reporters and videographers);
(b) Counsel of record for the Parties;
(c) A Party, or a former or present administrator, officer, employee, director, manager, member or shareholder of a Party deemed necessary by counsel of record for the ...

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