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Cuccia v. Protective Life Insurance Co.

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

October 16, 2019

KRISTEN CUCCIA, Plaintiff,
v.
PROTECTIVE LIFE INSURANCE COMPANY, Defendant.

          STIPULATED ORDER FOR THE PRODUCTION AND EXCHANGE OF CONFIDENTIAL INFORMATION

          DAVID C. KEESLER UNITED STATES MAGISTRATE JUDGE

         IT IS HEREBY ORDERED by the Court that the following restrictions and procedures shall apply to certain information, documents, and excerpts from documents that are produced, supplied, or exchanged between the parties in the above-styled action.

         1. Counsel for any party may designate any document or information contained in a document as confidential if counsel determines, in good faith, that such designation is necessary to protect the interests of the client. Information and documents designated by a party as confidential will be labeled “CONFIDENTIAL”. “CONFIDENTIAL” information or documents may be referred to collectively herein as “Confidential Information”. The designation of Confidential Information shall be made in the following matter:

a. In the case of documents: (i) by affixing the legend “CONFIDENTIAL” to each page containing any Confidential Information; or (ii) in the case of electronically stored information produced in native format, by including “CONFIDENTIAL” in the file or directory name, or by affixing the legend “CONFIDENTIAL” to the media containing the discovery material (e.g., CD-ROM, floppy disk, DVD);
b. In the case of depositions or other pre-trial testimony: (i) by a statement on the record, by counsel, at the time of such disclosure or before the conclusion of the deposition or testimony; or (ii) by written notice, sent to all parties within ten (10) days of the deposition or other pretrial testimony, provided that only those portions of the transcript designated as “CONFIDENTIAL” shall be deemed Confidential Information; and
c. In the case of any other discovery material, by written notice that the material constitutes Confidential Information.

         2. Unless otherwise ordered by the Court, or otherwise provided for herein, the Confidential Information disclosed will be held and used by the person receiving such information solely for use in connection with the above-captioned matter and for no other purpose.

         3. In the event a party challenges another party's “CONFIDENTIAL” designation, counsel shall make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party may thereafter seek resolution by the Court. Nothing in this Order constitutes an admission by any party that Confidential Information disclosed in this case is relevant or admissible. Each party specifically reserves the right to object to the use or admissibility of all Confidential Information disclosed, in accordance with applicable law.

         4. Confidential Information shall not be disclosed to any person, except:

a. The requesting party and counsel;
b. Employees or agents of such counsel assigned to and necessary to assist in the above-captioned litigation;
c. Consultants or experts to the extent deemed necessary by counsel;
d. Any person from whom testimony is taken or is to be taken, except that such a person may only be shown Confidential Information during and in preparation for his/her testimony and said person may ...

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