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Remington v. J.B. Hunt Transport, Inc.

United States District Court, D. Massachusetts

November 4, 2016

WILLIAM REMINGTON and MUSAN DURAKOVIC, on behalf of themselves and others similar situated, Plaintiffs,
v.
J.B. HUNT TRANSPORT, INC., DEFENDANT. ABE SILFANI, on behalf of himself and others similar situated, Plaintiffs,
v.
J.B. HUNT TRANSPORT, INC., DEFENDANT.

          Maura A. Greene, LAW OFFICE OF MAURA GREENE LLC

          J.B. HUNT TRANSPORT, INC., By its attorneys, Stephen T. Melnick David Casey, Stephen T. Melnick LITTLER MENDELSON, P.C

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         This matter comes before the Court, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, for the entry of a Protective Order governing the disclosure of confidential information by Defendant J.B. Hunt Transport, Inc. (“Defendant”) and Plaintiffs William Remington, Musan Durakovic and Abe Silfani (collectively, “Plaintiffs”) (each a “Disclosing Party” and collectively, the “Disclosing Parties”) during this lawsuit. The Disclosing Parties have agreed, as set forth in this Stipulated Confidentiality Agreement and Protective Order, to treat certain information as “Confidential” and subject to the protections afforded herein. As such, the Parties hereby stipulate and request that the Court enter a mutual protective order pursuant to Fed.R.Civ.P. 26 (as amended), as follows:

         1. Definition of “Documents or Information.”

         The term “documents or information” shall be synonymous in meaning and equal in scope to the usage of this term in Rule 34 of the Federal Rules of Civil Procedure, as amended.

         2. Designation and Use of Confidential Material.

         A Disclosing Party may designate as “Confidential” any documents or information produced in response to discovery requests or subpoenas which, in good faith, such Disclosing Party deems confidential, including without limitation, any documents or information (a) concerning any current or former employee or independent contractor of Defendant, including without limitation documents containing compensation-related information, health or medical-related information, social security numbers, home addresses, or home telephone numbers, (b) concerning any current, former, or prospective customer or business partner of Defendant, (c) concerning financial or business information of a Disclosing Party, (d) concerning proprietary, confidential or trade secret information of a third party, or other information that a Disclosing Party is bound to keep confidential by agreement with a third party, (e) concerning Plaintiffs' compensation-related information, health or medical-related information, information relating to tax filings, social security numbers, home addresses, or home telephone numbers, or (f) concerning any other personal, sensitive, proprietary, confidential or trade secret information of a Disclosing Party. Such designation shall be made by stamping or otherwise affixing a label or sticker stating “CONFIDENTIAL” to the documents or information so designated at the time of their production.

         Documents previously produced may be retroactively designated, by a Disclosing Party producing the document or by another Disclosing Party, by notice in writing identifying each such document Bates number within a reasonable time before trial. Documents produced without designation or with improper designation may be retroactively designated in the same manner, within a reasonable time before trial and shall be treated as confidential from the date written notice of the designation is provided to the Receiving Party. In the event of any change in designation pursuant to this paragraph, the party making the change shall promptly provide substitute copies of all documents as to which confidential status is claimed, with the replacement documents to bear a stamp, label, or sticker identifying the document as Confidential. Thereafter, the original, incorrectly designated documents (and all copies thereof) shall be promptly destroyed or returned to the designating party, with confirmation in writing upon request.

         Information disclosed or discussed in a deposition may be designated as “Confidential” by any Disclosing Party by so indicating on the record at the time of the deposition or, within thirty (30) days after receipt by the Disclosing Party of the applicable deposition transcript, by notifying counsel for the other Disclosing Party in writing as to which portions of the deposition transcript contain “Confidential” information.

         All documents or information marked or designated “Confidential” in accordance with this Protective Order shall be used solely for the purpose of conducting the above-captioned proceeding (the “Proceeding”), and not for, or in connection with, any other cases or disputes or for any other purpose. A recipient of any “Confidential” documents or information shall not disclose to anyone not specified in Paragraph 3 of this Protective Order any “Confidential” documents or information without the prior written consent of the Disclosing Party who produced such documents or information. Nothing contained in this Protective Order shall affect the right of a Disclosing Party to use or disclose materials that such Disclosing Party has produced and designated “Confidential” as such Disclosing Party sees fit; however, if a Disclosing Party uses or discloses the documents in a manner inconsistent with the designation of the documents as Confidential, and such use or disclosure is not inadvertent or unintentional, and is left uncorrected upon discovery of such use or disclosure, the documents will not be deemed Confidential for purposes of this Protective Order. All “Confidential” documents or information obtained by any person shall be maintained carefully so as to preclude access by persons who are not entitled to receive such documents or information.

         3. Disclosure of “Confidential” Documents or Information.

         Other than at trial, a deposition related to this Proceeding, or a hearing or conference regarding any motion in this Proceeding, documents or information marked or designated as “Confidential” may not be disclosed or made available by a recipient of such documents or information to any person other than:

(a) William Remington, Musan Durakovic and/or Abe Silfani;
(b) current or former employees of Defendant, whose assistance is needed in the prosecution or defense ...

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