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Platinum Press, Inc. v. Douros-Hawk

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

March 19, 2019

PLATINUM PRESS, INC., Plaintiff,
v.
DANIELLE DOUROS-HAWK, Defendant.

          William S. Cherry III, NC Bar No. 33860 Manning, Fulton & Skinner, P.A. Attorney for Defendant

          Kevin V. Parsons NC Bar No: 19226 Philip A. Hinson NC Bar No. 42907 Attorneys for Plaintiff

          CONSENT PROTECTIVE ORDER

          GRAHAM C. MULLEN, UNITED STATES DISTRICT JUDGE.

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, upon joint motion by the parties and it appearing that the discovery process in this action will involve the production of documents and information that parties and non-parties may contend is confidential and/or proprietary and that good cause exists for the entry of an Order limiting the disclosure of such information, the Court hereby GRANTS the parties' joint Motion and enters the following Protective Order to govern discovery and exchange of documents, electronic data, things, information, testimony, and/or other evidence that the parties, or any non-parties, may consider to be confidential information:

         DEFINITIONS

         For purposes of this Order, the following terms shall have the following meanings:

         A. “Order” means the executed version of this Consent Protective Order executed and entered by the Court in the above-captioned case.

         B. “Party” or “Parties” means Plaintiff Platinum Press, Inc. and Defendant Danielle Douros-Hawk.

         C. “Proceedings” means the above-captioned lawsuit currently pending before the undersigned or litigation relating to the subject matter of the above-captioned lawsuit.

         D. “Document(s)” shall be construed in its broadest sense and in accordance with the Rules of Federal Procedure and means information in any form whatsoever, including deposition testimony, all written, printed, electronically stored, recorded, taped, digitally encoded, graphic, photographic, or other information and all copies, reproductions, summaries, translations and drafts thereof, including all copies bearing notations and marks not found on the original.

         E. “Confidential Information” means either Documents or parts of Documents and the information contained therein that a Party or Non-Party reasonably and in good faith determines to constitute or concern (1) trade secrets or other confidential research or development, (2) commercial and proprietary information such as information related to a Party's customers, vendors, suppliers, sales, marketing, pricing, debts or revenues, (3) personnel records, (4) information subject to confidentiality agreements, (5) financial information or (6) any other confidential or proprietary matter the disclosure of which would competitively disadvantage the Producing Party (as that term is defined in Paragraph H of the Definitions below) and that are marked as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS ONLY” (as that term is defined herein) through the procedures established in this Order and includes Confidential Information in its original form, in copies, and in any form into which it may be converted or used. Confidential Information may be marked either “CONFIDENTIAL - ATTORNEYS ONLY” (as that term is defined herein) or “CONFIDENTIAL.”

         F. “CONFIDENTIAL - ATTORNEYS ONLY” means either Documents or parts of Documents and the information contained therein that a Producing Party and the Producing Party's counsel reasonably, with diligent scrutiny and care, and in good faith determines meets the definition of “Confidential Information” and the disclosure of which would cause actual harm or substantial prejudice to the Producing Party. Documents or parts of documents meeting the foregoing definition of “CONFIDENTIAL - ATTORNEYS ONLY” shall be marked as “CONFIDENTIAL - ATTORNEYS ONLY” through the procedures established in this Order.

         G. “Non-Party” means a person or entity who is not identified as a Party in the caption, but who produces Confidential Information to one or more Parties in response to a subpoena, or otherwise.

         H. “Producing Party” means any Party or Non-Party producing requested information or documents pursuant to a discovery request or subpoena.

         GENERAL PROVISIONS

         1. This Order applies to all Documents submitted, filed, taken, presented, or produced by a Party or any Non-Party to any other Party in connection with the Proceedings.

         2. The Parties wish to preserve Confidential Information in Documents and hereby agree to abide by the provisions of this Order.

         DESIGNATION OF ...


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