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Martin v. Harrah's NC Casino Co., LLC

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

August 7, 2019

KENNY MARTIN, Plaintiff,
v.
HARRAH'S NC CASINO COMPANY, LLC and BROOKS ROBINSON, Defendants.

          COZEN O'CONNOR Patrick M. Aul, NC Bar No. 39506,

          Susan N. Eisenberg, FL Bar # 174203 Pro Hac Vice Motion to Follow Attorneys for Defendants,

          WYCHE, P.A. William M. Wilson, III, Esq. Counsel for Plaintiff

          PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

          David C. Keesler United States Magistrate Judge

         Upon the joint request of the parties in the above-referenced matter for a Protective Order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby ORDERED that the following provisions shall govern confidentiality in Kenny Martin v. Harrah's NC Casino Company, LLC and Brooks Robinson (the “Action”):

         1. Introduction. Any party in this Action, and third parties subpoenaed by one of the parties, may designate as CONFIDENTIAL (“Designating Party”) documents (whether in hard copy or computer readable form), things, pleadings, deposition transcripts, answers to interrogatories, responses to requests for admissions, exhibits, and any other information produced, prepared, or discovered in this Action that contain Confidential Information, as defined in Paragraph 2. All such information, documents, excerpts from documents, testimony, and other materials will constitute “Designated Material” under this Order.

         2. Confidential Information. Except as provided below, all documents and information produced by the Parties in this litigation, and by third parties subpoenaed by one of the parties, that are labeled in good faith by counsel as CONFIDENTIAL within the meaning of Federal Rule of Civil Procedure 26(c) shall be maintained confidentially and used solely for purposes of this action. Confidential Information includes, but is not limited to, any confidential or non-public information about Harrah's NC Casino Company, LLC (“Harrah's), including but not limited to an unredacted copy of the Amended and Restated Management Agreement Between the Eastern Band of Cherokee Indians and Harrah's; any other proprietary or sensitive Harrah's business information; trade secrets; financial records; commercial records; customer or employee information; and personnel and other similar records of Harrah's. The parties hereby agree to abide by the terms of this Order upon its execution and filing with the Court, even though not yet entered by the Court.

         The following documents or information shall not be held as Confidential Information by the Parties subject to this Order:

(a) documents or information which at the time of disclosure are part of the public domain or record;
(b) documents or information which after its disclosure becomes part of the public domain or record through no act, omission, or fault of the Parties hereto; and
(c) documents or information which are rightfully in the possession of a Receiving Party, its counsel of record, or experts, under no obligation of confidence.

         3. Confidential-Attorneys' Eyes Only Information. CONFIDENTIAL-ATTORNEYS' EYES ONLY means CONFIDENTIAL, non-public information that the Designating Party reasonably and in good faith believes, consistent with Fed.R.Civ.P. 26(c)(1)(G), is so highly sensitive that its disclosure to a receiving party could result in significant competitive or commercial disadvantage to the Designating Party.

         4. Designation and Identification Of Confidential Information. CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY material shall be designated as follows:

(a) A party who wishes to designate tangible Confidential Information subject to this Order shall stamp or otherwise mark each page of the document CONFIDENTIAL or ...

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