Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Roberts v. Yale Security, Inc.

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

February 4, 2019

EDGAR ROBERTS, Plaintiff,
v.
YALE SECURITY, INC. D/B/A NORTON DOOR CONTROLS, Defendant.

          JOINT PROTECTIVE ORDER

          W. CARLETON METCALF UNITED STATES MAGISTRATE JUDGE.

         To adequately protect material entitled to be kept confidential, expedite the flow of discovery and facilitate the prompt resolution of disputes over confidentiality, it is HEREBY ORDERED that:

         1. Documents or information produced or provided by the parties during the course of discovery in the above-styled matter may be designated as “Confidential Information” so long as the party who seeks confidentiality has a good faith belief that such document or information is entitled to confidentiality under the terms of this Order.

         2. For purposes of this Order, “Confidential Information” means (a) any personnel or personal information of current or former employees of Defendant, its parent, subsidiaries, or affiliated or related entities (hereinafter “Related Entities”), (b) any document or information designated as confidential in accordance with paragraph 6 of this Order, and (c) any aggregation of Confidential Information. The identification of an individual document or category of documents or information as Confidential Information under paragraphs 2(b) or 2(c) may be challenged pursuant to paragraph 10 of this Order.

         3. For purposes of this Order, “Document” means all written, recorded, or graphic material, in hard copy or electronic format, including but not limited to deposition transcripts and exhibits, trial and hearing transcripts and exhibits, pleadings, motions, affidavits, and briefs that may quote, summarize, or contain Confidential Information.

         4. For purposes of this Order, “Producing Party” means a party that produces Confidential Information or other information in connection with this litigation.

         5. For purposes of this Order, “Recipient” means a named party in this litigation (or counsel thereto and their agents) who receives Confidential Information or other information in connection with the litigation.

         6. The Producing Party may designate as Confidential Information any information it believes to be confidential, including, without limitation, (i) non-public information about a past, present or potential employee of Defendant or its Related Entities, including personnel records, evaluations, investigations, compensation levels, databases, surveys, statistical analyses, analyses of personnel practices, reports or complaints, responses to reports or complaints, or other information incorporating or aggregating information pertaining to individuals, and (ii) trade secrets or other non-public proprietary, confidential, strategic, financial, customer, or commercial information, data or research of Defendant or its Related Entities. To designate Confidential Information on Documents, the Producing Party shall place a legend or stamp upon the Document indicating such in a way that brings the designation to the attention of a reasonable examiner, or otherwise puts the Recipient on reasonable notice that it contains Confidential Information. To designate Confidential Information in testimony (or in exhibits referred to therein), the Producing Party shall (a) make an oral statement to that effect on the record, or (b) notify the Recipient in writing at any time up until twenty (20) days after receipt of the transcript.

         7. The Recipient of Confidential Information shall use that information solely in connection with this litigation, and shall not disclose Confidential Information to any person except:

a) Plaintiff, in accordance with the procedures set forth in paragraph 8 of this Order;
b) The Court and its officers (including court reporters), consistent with the procedures set forth in paragraph 14 of this Order;
C)Counsel of record in this action and employees of counsel in this action who have been engaged in the conduct of this litigation;
d) Defendant's or its Related Entities' in-house counsel;
e) Experts or litigation consultants engaged by counsel to assist in this litigation, provided that these expert witnesses or litigation consultants expressly agree to be bound by the terms of this Order and not to ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.