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Sempowich v. Tactile Systems Technology, Inc.

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

March 12, 2019

TRACY SEMPOWICH, Plaintiff,
v.
TACTILE SYSTEMS TECHNOLOGY, INC. d/b/a TACTILE MEDICAL, Defendant.

          Kristin Berger Parker, MN Bar No. 0389249 Carroll Theresa Wright, MN Bar No. 0399169 STINSON LEONARD STREET, LLP Attorneys for Defendants

          Kathryn F. Abernethy N.C. Bar No. 43933 THE NOBLE LAW FIRM, PLLC Attorneys for Plaintiff

          Theresa M. Sprain, NCSB No. 24540 Rebecca C. Fleishman, NCSB No. 41233 WOMBLE BOND DICKINSON (US) LLP Attorneys for Defendants

          PROTECTIVE ORDER

         The parties to this action, through their respective undersigned attorneys, hereby stipulate and agree that certain information, documents, and other discovery information provided or disclosed by the parties and by other persons or entities may contain confidential proprietary business or financial information regarding the defendant, personnel information on individual parties or non-parties, and private financial and personal information regarding the Plaintiff or non-parties.

         THEREFORE, IT IS HEREBY STIPULATED, AGREED, AND ORDERED that pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the following confidentiality provisions shall govern all information and documents disclosed in discovery in this action:

         1. As used in the Protective Order, these terms have the following meanings:

"Attorneys" means counsel of record;
"CONFIDENTIAL" documents are documents designated pursuant to paragraph 4;
"Confidential - Attorneys' Eyes Only" documents as documents designated pursuant to paragraph 6;
"Documents" are all materials within the scope of Fed.R.Civ.P. 34; "Outside Vendors" means messenger, copy, coding, and other clerical-services vendors not employed by a party or its Attorneys; and "Written Assurance" means an executed document in the form attached as Exhibit A.

         2. The parties' discovery will entail production of confidential documents and materials, including the following:

a. Defendant's personnel information regarding Plaintiff and potentially other current or former employees. Such information may contain, but is not limited to, sensitive personal identification information, dependent and/or spouse or family information, tax withholding documents, insurance and retirement plan enrollment information, and similar documents, or information provided by the employee or about the employee by a third party, that the employee reasonably believed that Defendant would maintain as a confidential employment record.
b. Documents containing Defendant's trade secret, confidential, proprietary, financial, and business information.
c. Documents, records, or other information that provide names, addresses, telephone numbers, employment dates, job titles, compensation, disciplinary action information, or other details about Defendant's current or former employees.
d. Information regarding income, tax withholding and pay records of Plaintiff, employees of Defendant, or non-parties; e. Documents and information containing confidential and/or protected health information of any person, which may be redacted by the parties if practicable, unless discoverable under Rule 26; and f . Any other category of information to which this Court subsequently affords confidential status.

         3. The parties stipulate, and the Court finds that documents and information such as described in Paragraph 2 should be protected from unreasonable disclosure pursuant to Rule 26(c) of the Federal Rules of Civil Procedure.

         4. Any party, in good faith, may designate information like that described in Paragraph 2 above (and in the related subparagraphs) as "CONFIDENTIAL," and subject to the protections in this Order, regardless of who produced or provided the information, subject to the procedure provided by Paragraph 5, below. Information designated as "CONFIDENTIAL" shall be used solely for purposes of ...


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