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Sage Therapeutics, Inc. v. Sage Naturals, Inc.

United States District Court, D. Massachusetts

January 31, 2018

SAGE THERAPEUTICS, INC., Plaintiff,
v.
SAGE NATURALS, INC., Defendant.

          STIPULATED PROTECTIVE ORDER

          Hon. Richard G. Stearns United States District Judge.

         WHEREAS, the parties believe that it would serve their interests to conduct discovery under a protective order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure; and

         WHEREAS, the parties have agreed to this Stipulated Protective Order, subject to approval of the Court;

         IT IS HEREBY ORDERED that:

         1. Any party to this action, and any non-party from whom discovery is sought in connection with this action may designate as

         (a) “Confidential”; or

         (b) “Highly Confidential/Attorneys' Eyes Only” any documents, things, interrogatory answers, responses to requests for admissions, trial or deposition testimony, or other material that contains Confidential Information as set forth below.

         2. Confidential Information.

         As used in this Protective Order, the term “Confidential Information” means material or information not generally known to the public that the producing or disclosing party in good faith believes to incorporate sensitive business or commercial information, trade secrets, know-how, proprietary data, or private or personal information. Such material may be designated as “Confidential.

         3. Highly Confidential Information/Attorneys' Eyes Only.

         As used in this Protective Order “Highly Confidential Information - Attorneys' Eyes Only” means “Confidential Information” as set forth in paragraph 2 that the producing or disclosing party believes in good faith is of such a sensitive, competitive, or secret nature that disclosure of such information to any other party or non-party reasonably poses the risk of competitive injury. Examples of such information may include but are not limited to proprietary engineering drawings or specifications, source code, customer lists, invention notebooks, or other trade secrets, as well as internal financial analyses and data and business and product plans. Such material may be designated as “Highly Confidential/Attorneys' Eyes Only.

         4. Designation of Confidential Materials.

         If the disclosing or producing party or non-party believes in good faith that information is within the definitions in paragraphs 2 or 3, above, it may so designate that information as set forth below. Information so designated shall include all copies, excerpts, summaries, indices, abstracts, or copies of such information, regardless of the manner disclosed, including designated information disclosed during a deposition, in a document, in an interrogatory answer, by production of tangible evidence, during a hearing or trial, in responses to requests for admissions or otherwise disclosed in connection with this action.

         5. Disclosure of Confidential Information. Until or unless the Court rules otherwise, material marked or otherwise designated “Confidential” under paragraph 2, shall be maintained in confidence by the person to whom such material is produced and shall not be disclosed to any person without the express written consent, or consent on the record, of the producing party except that material marked or otherwise designated as “Confidential” under paragraph 2 may be disclosed to:

(a) Outside counsel for the respective parties, and the secretarial, clerical, litigation support, and paralegal personnel employed or retained by such counsel.
(b) A single officer, director, or employee of the corporate party that the corporate party shall designate in writing prior to disclosure of any designated information to assist in the preparation of this litigation. The parties agree on their own behalf and on behalf of any in-house support staff to be bound by the provisions of the undertaking attached as Exhibit A, and to have each person so designated under this paragraph to sign the undertaking attached as Exhibit A before receiving any Confidential Information.
(c) Outside experts who are not officers, directors, employees, shareholders, or consultants of a party to this action, and who have been retained in connection with this action, and who agree that they will not use Confidential Information for any purpose other than to prepare and/or provide expert testimony in this action and who have been given a copy of this Stipulated Protective Order and its provisions have been explained to them by an attorney and such expert has signed an undertaking in the form of the attached Exhibit A. Any outside expert proposed to be given access to Confidential Information must be identified in writing by the party seeking to qualify such person under this paragraph along with a copy of their qualifications as required by Fed.R.Civ.P. 26. Any party who objects to such person's designation under this paragraph (c) will give notice in writing of the objection and the basis for it in writing within 5 business days. No Confidential Information shall be disclosed to any person to whom such an objection has been made, and it shall be the burden of the party seeking to qualify such person under this paragraph to obtain a ruling from the Court that such a person may be so designated.
(d) The Court and its employees (including court reporters, persons operating video equipment at depositions, translators, and any special master appointed by the Court) whose function requires them to have access to material designated as ...

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