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Genzyme Corp. v. Dotter

United States District Court, D. Massachusetts

October 11, 2018

GENZYME CORPORATION, Plaintiff,
v.
THOMAS DOTTER, Defendant.

          GENZYME CORPORATION, James W. Bucking Michael J. Licker FOLEY HOAG LLP.

          THOMAS DOTTER C. Max Perlman HIRSCH ROBERTS WEINSTEIN LLP.

          CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          HON. RICHARD G. STEARNS JUDGE.

         This Confidentiality Agreement and Protective Order (“Protective Order”) is entered into by Plaintiff Genzyme Corporation and Defendant Thomas Dotter (the “parties”) in order to protect from disclosure what the parties deem to be confidential information. The Protective Order permits parties to designate documents and information as “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY.” Documents and information so designated may only be disclosed or used as further provided herein. Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby stipulated and agreed by and between the parties, through their respective counsel and subject to the approval of this Court, that this Protective Order be entered in this action.

         STIPULATED, AGREED, AND ORDERED:

         1. All documents or information produced by any party in discovery proceedings in the above-entitled action designated as “CONFIDENTIAL” shall be subject to the terms of this Protective Order and shall be used only for the purposes of the above-entitled civil action and not for any other litigation, or for any business or other purpose whatsoever, and shall not be disseminated to any non-parties to this litigation, including without limitation Novartis Pharmaceuticals Corp.

         2. Any party producing information (whether by document, by testimony, by interrogatory answer, or otherwise) in the course of discovery herein which relates to confidential or proprietary commercial, business, personal or financial information may designate such information “CONFIDENTIAL.” Documents (and the contents thereof) and other information designated as “CONFIDENTIAL” shall be maintained in confidence solely for use in this civil action and such materials shall not be disclosed to any person except:

(a) outside counsel representing the parties to this action, and employees of their respective firms;
(b) parties to this action, including employees and in-house counsel;
(c) the Court and its support personnel;
(d) a deponent or witness who either (i) is an officer, director, partner, attorney, employee or agent of the producing party [producing party can show whatever it likes to its employees], or (ii) has signed a statement in the form of Exhibit A hereto stating that they have read this Stipulation and Order and agree to be bound by its terms;
(e) consulting and testifying experts or other consultants retained to assist outside counsel of record for the purpose of assisting in the preparation for trial of this action and who have signed a statement in the form of Exhibit A hereto stating that they have read this Stipulation and Order and agree to be bound by its terms;
(f) copying or imaging services, court reporters, videographers, non-technical consultants, graphics personnel, jury consultants and translators associated with or retained by a party in connection with this action; and
(g) any other person as to whom the producing party agrees in writing, or as to whom a court order has been obtained ...

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