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Huber Technology, Inc. v. Gowing Contractors Ltd

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

June 24, 2019

HUBER TECHNOLOGY, INC., Plaintiff,
v.
GOWING CONTRACTORS LTD, Defendant.

          Steele B. Windle, III, Steven A. Bimbo, N.C., Attorneys for Plaintiff.

          Mathew E. Flatow, David A. Swenton, Attorneys for Defendant.

          STIPULATED PROTECTIVE ORDER

          David C. Keesler United States Magistrate Judge.

         In order to preserve and maintain the confidentiality of certain information served, produced, or otherwise disclosed or communicated by, between, or among the parties to this action, the Court, all parties to this action and/or third persons or entities hereby stipulate and agree, and IT IS ORDERED THAT:

         1. Information or documents served, produced, or otherwise disclosed or communicated by any person or entity in connection with this action (“Materials”) that constitutes or contains confidential or proprietary information including, without limitation, information or documents that fall within one or more of the following categories shall be referred to as “Protected Documents”:

a. materials related to the confidential and proprietary business information of Huber Technology, Inc. and any information derived from such information or documents, including, without limitation, written discovery responses, extracts, memoranda, notes, records or transcripts of deposition testimony, and correspondence quoting from or summarizing such information;
b. materials related to the confidential and proprietary business information of Gowing Contractors Ltd and any information derived from such information or documents, including, without limitation, written discovery responses, extracts, memoranda, notes, records or transcripts of deposition testimony, and correspondence quoting from or summarizing such information;
c. materials related to the confidential and proprietary business information of persons and entities not party to this action including, without limitation, Kusters Zima Corporation and any information derived from such information or documents, including, without limitation, written discovery responses, extracts, memoranda, notes, records or transcripts of deposition testimony, and correspondence quoting from or summarizing such information;
d. information that reveals trade secrets;
e. research, technical, commercial or financial information that the party has maintained as confidential;
f. personal identity information, including Social Security numbers;
g. income tax returns, including W-2 forms; or
h. personnel or other employment records of a person who is not a party to the case. When used in this Protective Order, the word “documents” is used in its broadest sense and means all written and computerized materials, videotapes, and all other tangible items and items in magnetic or electronic form. Protected Documents designated by any party or third party as either or both “Confidential-Subject to Protective Order” or “For Attorney Eyes Only, ” and served, produced, or otherwise communicated in this action shall be Protected Documents and given confidential treatment as described below.

         2. Materials produced or otherwise disclosed or communicated in this action that a person or entity deems to constitute a Protected Document may be designated as such as follows: (1) by the person or entity producing, disclosing, or communicating the materials marking the document or thing with a legend stating “Confidential-Subject to Protective Order” or “For Attorney Eyes Only, ” or by either or both of such written designation(s) using Bates number type specifications or other conspicuous designation; or (2) by any party receiving them making such written or, if during a proceeding with a court reporter present, on-the-record designation. Any written discovery response marked ...


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