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Henry v. Vaughn Industries, LLC

United States District Court, E.D. North Carolina

April 24, 2019

SEAN HENRY, Plaintiff,



         The parties to this Stipulated Protective Order have agreed to the terms of this Order. Accordingly, it is ordered:

         1 Scope. All documents produced in the course of discovery, including initial disclosures, all responses to discovery requests, all deposition testimony and exhibits, other materials which may be subject to restrictions on disclosure for good cause and information derived directly therefrom (hereinafter collectively "documents"), shall be subject to this Order concerning confidential information as set forth below. As there is a presumption in favor of open and public judicial proceedings in the federal courts, this Order shall be strictly construed in favor of public disclosure and open proceedings wherever possible. The Order is also subject to the Local Rules of this District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2 Form and Timing of Designation. A party may designate documents as confidential and restricted in disclosure under this Order by placing or affixing the word "CONFIDENTIAL" on the document in a manner that will not interfere with the legibility of the document and that will permit complete removal of the CONFIDENTIAL designation. Documents shall be designated CONFIDENTIAL prior to or at the time of the production or disclosure of the documents. The designation CONFIDENTIAL does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order.

         3 Documents Which May be Designated CONFIDENTIAL. Any party may designate documents as CONFIDENTIAL upon making a good faith determination that the documents contain information protected from disclosure by statute or that should be protected from disclosure as confidential personal information, medical or psychiatric information, trade secrets, proprietary information, personnel records, or such other sensitive commercial information that is not publicly available. Public records and other information or documents that are publicly available may not be designated as CONFIDENTIAL.

         4 Depositions. Deposition testimony shall be deemed CONFIDENTIAL only if designated as such. Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL. Alternatively, any party may designate information disclosed at such deposition as confidential by notifying all parties and the court reporter in writing, within ten (10) days of receipt of the transcript, of the specific pages and lines of the transcript which are confidential. Thereafter, the deposition transcripts and any of those portions so designated shall be protected as CONFIDENTIAL, pending objection, under the terms of this Order.

         5 Protection of Confidential Material.

5.1 General Protections. Documents designated CONFIDENTIAL under this Order shall not be used or disclosed by the parties, counsel for the parties or any other persons identified in ¶ 5.2 for any purpose whatsoever other than to prepare for and to conduct discovery and trial in this action, including any appeal thereof.
5.2 Limited Third-Party Disclosures. The parties and counsel for the parties shall not disclose or permit the disclosure of any CONFIDENTIAL documents to any third person or entity except as set forth in subparagraphs 5.2.1-5.2.5 of this section. Subject to these requirements, the following categories of persons may be allowed to review documents that have been designated CONFIDENTIAL:
5.2.1 Counsel. Counsel for the parties and employees and agents of counsel who have responsibility for the preparation and trial of the action; 5.2.2 Parties. Parties and management-level employees of a party to this Order;
5.2.3 Court Reporters and Other Courtroom Personnel. Court reporters and recorders engaged for depositions, and the courtroom personnel at any deposition, pretrial hearing, trial or other proceeding held in connection with this action;
5.2.4 Mediator. Any person designated as a mediator by order of the Court or agreement of the parties who agrees to be bound by this Order;
5.2.5 Consultants, Investigators and Experts. Consultants, investigators, or experts (hereinafter referred to collectively as "experts") employed by the parties or counsel for the parties to assist in the preparation and trial of this action or proceeding, but only after such persons have completed the certification contained in Attachment 1, ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE BOUND; and
5.2.6 Others by Consent. Other persons only by written consent of the producing party or upon order of the Court and on such conditions as may be agreed or ordered. All such persons shall execute the certification contained in Attachment 1, ...

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