United States District Court, W.D. North Carolina, Charlotte Division
CHRISTINA M. PITTS, Plaintiff,
CAROMONT HEALTH, INC., Defendant.
J. Angel N.C. Bar No. 33559 THE ANGEL LAW FIRM, PLLC
CONSENT PROTECTIVE ORDER
C. Keesler United States Magistrate Judge
it is hereby STIPULATED and AGREED between Plaintiff
Christina M. Pitts, and Defendant CaroMont Health, Inc.
(collectively “the Consenting Parties”), and it
is hereby ORDERED by the Court, that the following terms and
conditions shall govern the use and handling of Confidential
Information and documents produced by the Consenting Parties
in the above-captioned matter (“this
documents and data, including electronically stored
information, produced in the course of discovery, all
responses to discovery requests, and all deposition testimony
and deposition exhibits and any other materials which may be
subject to discovery shall be subject to this Consent
Protective Order (the “Protective Order”).
documents, data, and information obtained through discovery
in this Litigation shall be used only for the purposes of
prosecuting or defending this Litigation.
Information” shall mean any and all information
produced in the course of discovery or trial that a party
deems in good faith to contain medical, banking, tax, or
other sensitive financial information, any trade secrets of
any party or of a third party, or any contracts with
third-parties that may contain confidential information or be
subject to non-disclosure obligations. The parties may
mutually agree to designate other documents or information as
“Confidential Information” that is not otherwise
defined herein and such stipulated designation shall be
effective to protect such information under this Order. If
the parties cannot mutually agree that certain additional
information or documentation be designated as
“Confidential Information, ” the party requesting
the designation may promptly move the Court to amend or
extend the protections of this order to cover said
information or documentation. Prior to or while such motion
is pending the party requesting the designation shall produce
the subject documentation or information to counsel for the
opposing party who shall treat the same as
“Confidential Information” under this Order until
the Court rules on any such motion.
Access to Confidential Information.
to documents and information designated as CONFIDENTIAL shall
be restricted to the following persons:
(a) parties to this Litigation and the officers and employees
of the parties who are directly participating in the
prosecution or defense of this Litigation;
(b) law firms of record of the parties to this Litigation and
such firms' attorneys and staff;
(c) any person specially employed or engaged in this
Litigation by a party or its attorneys as an expert,
consultant, or vendor;
(d) the Court and its personnel;
(e) court reporters and videographers retained to transcribe
or record depositions and court ...