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Scott v. Iredell Statesville Schools Board of Education

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

February 19, 2019

MARLENE B. SCOTT Plaintiff,
v.
IREDELL STATESVILLE SCHOOLS BOARD OF EDUCATION, Defendant.

          Attorneys for Defendant Iredell-Statesville SCHOOLS Board of Education D. BETH LANGLEY, ELIZABETH L. TROUTMAN, SARAH M. SAINT, BROOKS, PIERCE, MCLENDON, HUMPHREY & LEONARD, L.L.P.

          Attorney for Plaintiff Marlene B. Scott, GERALDINE SUMTER, FERGUSON, CHAMBERS & SUMTER, P.A.

          CONSENT PROTECTIVE ORDER

          David C. Keesler United States Magistrate Judge.

         The Parties having agreed to the following, and for good cause shown, IT IS, THEREFORE, ORDERED as follows:

         1. Scope

         This Order applies to all products of discovery and all information derived therefrom, including, but not limited to, all documents, data compilations, electronically stored information, computer disks, objects or things, deposition testimony, affidavits, interrogatory/request for admission/request for production responses, or any other media on which information is recorded, and any copies, excerpts or summaries thereof, obtained by any party pursuant to the requirements of any court order, request for production of documents, request for admissions, interrogatory, or subpoena (collectively, “Discovery Materials”). This Order does not affect any person's or entity's use of its own information or documents, nor does it affect the use of any information or documents at trial.

         2. “Confidential” Material Defined

         For the purposes of this Order, Discovery Materials may be designated as “Confidential” pursuant to Paragraph 4 of this Order. A Designating Entity may designate as “Confidential” any discovery material it reasonably and in good faith believes to contain personally identifiable information of education records or other student information protected from disclosure by federal or state law, confidential personnel information protected from disclosure by state law, protected health information of any kind, other highly sensitive personal information, and/or any discovery material protected by the attorney-client privilege or work product doctrine.

         For the purposes of this Order, a “Designating Entity” is any party to this litigation that is producing information or documents in discovery in this action, as well as any third party who is producing the material pursuant to a subpoena in this action.

         For the purposes of this Order, “Designated Material” means any material that meets the definition of “Confidential” under this Order, and that has been so designated by any Designating Entity.

         3. Use of Designated Material

         Unless otherwise expressly permitted by this Court or by express written agreement of the parties, all Designated Material produced or discovered in this case shall be used solely for the prosecution or defense of this case, and shall not be used by any party, their counsel of record, or any other person to whom such Designated Material is disclosed for any other purpose, including, but not limited to, any other litigation or judicial proceedings, or any business, competitive, or commercial purpose or function. As described in Paragraph 7, any party filing designated material with the Court must seek to file such material under seal.

         4. Procedure for Designating Material

         A Designating Entity shall designate “Confidential” material in the following manners:

a. In the case of documents or other written materials, by affixing the word “Confidential” by stamp or other method which will make such word conspicuous to each page of the document the Designating Entity wishes to designate.
b. In the case of electronic data, including but not limited to information produced on a hard drive, cd-rom, dvd-rom, thumb drive, or other electronic media (“medium of production”), by providing written notice to all parties requesting production identifying the material being designated as “Confidential.” To the extent possible, the Designating Entity shall also label the medium of production with the appropriate designation. However, any failure or inability to affix such label to the medium of production shall not waive any protection provided by this Order.
c. In the case of depositions or other pretrial testimony in this action, by designating any portion or all of a deposition as “Confidential” by notifying the other parties on the record during the deposition, or alternatively, such Entity may designate information by notifying all the parties in writing, within fourteen (14) days of the receipt of the deposition transcript, of the specific pages and lines of the transcript which are to be regarded as “Confidential.” The parties shall automatically treat all information disclosed at a deposition as “Confidential” for fourteen (14) days after receipt of the final version of the transcript.
d. In the case of written discovery or pleadings, by affixing the word or phrase “Confidential” by stamp or other method to the portions so designated.

         Any party may designate discovery materials produced by any third party pursuant to a subpoena as “Confidential” by so informing all other parties and the producing third party. Third parties producing documents or other material pursuant to a subpoena in this case may also designate such documents or materials as “Confidential” pursuant to this Order.

         5. Permissible Disclosures of “Confidential” Material

         Except as otherwise agreed by the Designating Entity or as ordered by the Court, material designated as ...


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