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Colucci, Colucci, Marcus and Flavin, P.C. v. Citizens Bank of Massachusetts

United States District Court, D. Massachusetts

August 4, 2016

COLUCCI, COLUCCI, MARCUS, AND FLAVIN, P.C., Plaintiff,
v.
CITIZENS BANK OF MASSACHUSETTS, Defendant.

          Plaintiff, COLUCCI. COLUCCI, MARCUS, AND FLAVIN, P.C., By its Attorneys, Paul K. Flavin, Brendan R. Pitts, Colucci, Colucci, Marcus & Flavin, P.C.

          Defendant, CITIZENS BANK, N.A., By its Attorneys, Geoffrey W. Millsom, Brenna Anatone Force, Adler Pollock & Sheehan, P.C.

          STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED AND AGREED by the undersigned parties that:

         1. This Stipulation governs the use of all documents obtained from any of the undersigned parties during the course of the above-captioned action. If endorsed and ordered by the Court, the provisions set forth herein will apply to all parties in the litigation, whether presently existing or added in the future. This Stipulation does not restrict any party's use of discovery material that was not obtained in discovery, that is or becomes publicly available or that it obtains from any third party. All such discovery material obtained from the producing party shall be used only for purposes of this litigation (including alternative dispute resolution procedures and appeals, if any).

         2. At any time, any party may designate all or any part of such discovery material produced by them as confidential, to be treated in accordance with the provisions of this Stipulation. Such designation shall be in writing either in a letter identifying the discovery material(s) being designated, or by a stamp or other appropriate mark on the discovery material. A designation of "CONFIDENTIAL" will mean that the party believes in good faith that the document contains confidential material which is unavailable to the public.

         3. Counsel of record for the parties shall have the right to disclose confidential material pursuant to this agreement only to the following persons to the extent that their knowledge of such confidential material is necessary for the prosecution, defense or settlement of this matter:

(a) Parties;
(b) Counsel of record for the parties of record in this matter and the partners, associates and employees of such counsel to the extent reasonably necessary to render professional services in the litigation;
(c) Court personnel (including court reporters), including by way of briefs or other papers filed with the Court;
(d) Commercial photocopying firms;
(e) Any law enforcement agency or governmental body, upon request;
(f) Experts, consultants (including independent experts), and investigators, including the employees of such experts, consultants, or investigators, who are employed, retained, or otherwise consulted by counsel or a party for the purpose of analyzing data, conducting studies, or providing opinions to assist, in any way, in this matter. Access to confidential material shall be limited to what is reasonably required in the role of expert, consultant, and investigator. Such persons must agree in writing to be bound by the terms of this order;
(g) Litigation support firms retained by counsel or a party in order to assist in the prosecution or defense of this matter. Access to confidential material shall be limited to that which the litigation support firms reasonably require in their roles as litigation support firms;
(h) Any person that a party believes in good faith may be called to give testimony at any stage of the proceedings on matters relating to confidential material. Access to confidential material shall be limited to that which is necessary for the preparation and/or testimony of such witnesses. Such ...

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