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Knizley v. Chemline, Inc.

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

February 22, 2019

JAMES B. KNIZLEY, Plaintiff,
v.
CHEMLINE, INC. ET AL., Defendants.

          STIPULATED PROTECTIVE ORDER

          GRAHAM C. MULLEN, UNITED STATES DISTRICT JUDGE.

         Plaintiff James B. Knizely and Defendants Chemline, Inc. and John Pantanella HEREBY STIPULATE AND AGREE that the following Stipulated Protective Order be entered pursuant to Federal Rule of Civil Procedure 26(c), subject to approval of the Court:

         IT IS HEREBY AGREED AND ORDERED THAT:

         1. Discovery Materials

         Any documents, written discovery responses, deposition transcripts and exhibits, other responses to requests for information and/or other written information, whether produced voluntarily or involuntarily, either in response to discovery requests or to subpoenas in this litigation by any party or non-party (hereafter collectively “Discovery Materials”), may be designated by a producing party or non-party as “Confidential” under this Order.

         2. “Confidential” Discovery Materials

         Any party or non-party may designate any Discovery Materials “Confidential” which the producing party or non-party reasonably believes not to be in the public domain and contains any information of a type that the party or non-party regards as proprietary or confidential financial, business, technical, strategic, research, development, or commercial information or private personal information.

         3. Effect of Designation

         The designation of Discovery Materials as Confidential shall constitute a representation that the attorney for the producing party or non-party believes that there is a valid basis for such designation. However, the designation or failure to designate information as Confidential or may not be used against the producing party or non-party as an admission or concession that the designated information is or is not, in fact, confidential, proprietary, a trade secret, intellectual property, or otherwise sensitive.

         4. Scope of Order

         A. Discovery Materials to be covered by this Order shall include Confidential information, as defined above, that is set forth, revealed, or provided: (a) in response to written discovery requests; (b) in any documents, things, or premises made available for inspection or produced to the discovering party or produced in response to a subpoena; (c) during depositions upon oral or written examination; (d) in connection with any other discovery taken in this action, whether pursuant to the Federal Rules of Civil Procedure, informally, or by agreement; (e) in or accompanying correspondence to the receiving party; (f) in submissions to or before the Court, including testimony, briefs, exhibits, and declarations; and (g) in response to any Court Order.

         B. Information to be covered by this Order shall also include privileged information, as discussed below.

         5. Disclosure and Use of Confidential Discovery Materials

         Nothing in this Order shall restrict the ability of a party to disclose its own Confidential information. Confidential Discovery Materials shall be disclosed by the receiving party only to the following persons and used only for the litigation of this action, and any appeal therefrom:

a. Employees of a party to this action;
b. Outside counsel of record retained by Plaintiff or Defendants and who are members of a firm appearing before the Court in this action, together with other attorneys employed by these law firms and those attorneys' stenographic, clerical, paralegal, and other employees whose duties and responsibilities require access to Confidential information;
c. Court reporters, outside copy services, graphics consultants, translators, interpreters, and similar support ...

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