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Currie v. Murphy-Brown, LLC

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

February 4, 2019

ADRIAN T. CURRIE, Plaintiff,
v.
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.

          Ralph T. Bryant, Jr., Esquire, Attorney at Law, Attorney for Plaintiff Adrian T. Currie.

          STIPULATED PROTECTIVE ORDER

          ROBERT B. JONES, JR. UNITED STATES MAGISTRATE JUDGE.

         Adrian 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 litigation.

         During 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 ORDERED THAT:

         1. 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.

         2. Definition of Confidential Information.

         A Party 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.

         3. 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 Litigation;
(d) Outside experts or consultants who are retained on behalf of any of the Parties to assist in the preparation of this case;
(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 ...

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