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Atlantic Coast Marine Group, Inc. v. Newcomb

United States District Court, E.D. North Carolina

September 16, 2019

ATLANTIC COAST MARINE GROUP, INC., Plaintiff,
v.
MICHAEL GRANT NEWCOMB and MELODY BENSON, Defendants.

          E. Winslow Taylor, TAYLOR & TAYLOR, ATTORNEYS, AT LAW, PLLC Attorney for the Plaintiff

          Caroline Stutts, Attorney for Defendants.

          PROTECTIVE ORDER

          Robert B. Jones, Jr. United States Magistrate Judge.

         THIS MATTER is before the Court on the parties' Joint Motion for Protective Order. Having considered the Motion and reviewed the pleadings, the Court enters the following Order.

         IT IS, THEREFORE, ORDERED that the parties' Joint Motion for Protective Order is GRANTED, and the following PROTECTIVE ORDER is entered:

         THIS CAUSE coming on before the undersigned Judge upon the consent motion of Plaintiff and Defendants (collectively, the "Parties") pursuant to Fed.R.Civ.P. 26(c), and for good cause shown, the Court hereby approves and enters the following Protective Order.

         1. The "Litigation" shall mean the above-captioned lawsuit.

         2. "Discovery Materials" shall mean and include any document (whether in hard copy or electronic form), records, responses to discovery, whether documentary or oral, and other information provided, served, disclosed, filed, or produced, whether voluntarily or through discovery, in connection with this Litigation.

         3. "Producing Party" shall mean any party or non-party person or entity that provides, serves, files, or produces any non-public information in connection with this Litigation.

         4. Discovery Materials produced or disclosed in connection with the Litigation by a Producing Party that contain either: (1) non-public sensitive, commercial, financial, or proprietary information; or (2) non-public personal information concerning individuals, such as Social Security numbers, home telephone numbers and addresses, tax returns, personnel evaluations, and medical and banking information, may be designated "CONFIDENTIAL"' by the Producing Party. Discovery Materials designated "CONFIDENTIAL" shall be referred to herein as "Confidential Discovery Materials." The Parties further agree that reference to any category or type of Discovery Material above is not intended to and shall not be construed as an admission that the Discovery Material is not subject to an applicable privilege or protection, or that the Discovery Material is relevant, admissible, or reasonably calculated to lead to the discovery of admissible evidence.

         5. Confidential Discovery Material may be designated confidential by marking or stamping the page or pages containing such information as "CONFIDENTIAL" or, in the case of Confidential Discovery Material that cannot be so stamped or marked, pursuant to a letter from the Producing Party identifying such materials as Confidential.

         6. "CONFIDENTIAL" information and documents shall be maintained in strict confidence by the Parties who receive such documents or information, shall be used solely for the purposes of this Litigation, and shall not be disclosed to any person or entity, except:

(a) The United States District Court for the Eastern District of North Carolina or the United States Court of Appeals for the Fourth Circuit (the "Courts") and persons assisting the Courts or assisting in the Litigation process (including, but not limited to, court personnel, court reporters, stenographic reporters, and videographers);
(b) The attorneys of record in this Litigation and their partners, employees, associates, and/or contract attorneys who are assisting in the Litigation (collectively hereafter ...

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