United States District Court, E.D. North Carolina, Southern Division
ADRIAN T. CURRIE, Plaintiff,
MURPHY-BROWN, LLC. Defendant.
Melissa A. Romanzo, Hunton ANDREWS KURTH LLP, Sharon S.
Goodwyn, Hunton ANDREWS KURTH LLP, Reilly C. M~ore, HUNTON
ANDREWS KURTH LLP, Attorneys for Defendant Murphy-Brown, LLC.
T. Bryant, Jr., Esquire, Attorney at Law, Attorney for
Plaintiff Adrian T. Currie.
STIPULATED PROTECTIVE ORDER
B. JONES, JR. UNITED STATES MAGISTRATE JUDGE.
T. Currie ("Plaintiff) and Murphy-Brown, LLC d/b/a
Smithfield Hog Production ("Defendant")
(collectively, the "Parties"), have jointly
stipulated and agreed to the entry of this Stipulated
Protective Order ("Protective Order") governing the
production, possession, and use of confidential information
and documents produced or made available by any of them in
this case, the Parties may obtain information from one
another that is confidential, proprietary or otherwise
requiring or deserving confidential treatment. In order to
protect proprietary and confidential information, IT IS
Scope of Order. This Protective Order governs the
use and handling of documents, electronic information,
testimony, interrogatory responses and other information,
including all copies, excerpts and summaries thereof produced
or given by Defendant, Plaintiff, or other individuals or
entities in this Litigation. Confidential material or
information produced in this Litigation shall be used only
for the purpose of this Litigation, and not for any business
or competitive purposes whatsoever.
Definition of Confidential Information.
may designate as "Confidential" any (1) information
or (2) documents, transcripts of other materials containing
such information, produced in this Litigation that contains
confidential medical or confidential non-public employee,
human relations, financial, proprietary, commercial or other
information for which a good faith claim of need of
protection from disclosure can be made under the Federal
Rules of Civil Procedure and/or other applicable law
("Confidential Information"). The confidentiality
designations will be made by an attorney in conformance with
this Protective Order. All doubts are to be resolved in favor
of confidential treatment of any information exchanged by the
Parties to this action.
Persons Who May Access Confidential Information.
Absent written consent from the Producing Party or as
otherwise directed by the Court, Confidential Information may
be disclosed only to the following persons:
(a) Parties and employees of Parties who have a need for
access to the Confidential Information for this Litigation;
(b) Outside counsel of record for the Parties;
(c) In-house counsel for the Parties who are actively
involved in assisting with the prosecution or defense of this
(d) Outside experts or consultants who are retained on behalf
of any of the Parties to assist in the preparation of this
(e) The Court, court reporters, videographers, stenographers,
and court personnel involved the litigation of this case;
(f) Any potential witness or deponent, but only to the extent
necessary for the purpose of preparing for a ...