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Ferrari v. Vitamin Shoppe, Inc.

United States District Court, D. Massachusetts

November 19, 2018

RICHARD FERRARI, individually and on behalf of all others similarly situated, Plaintiff,
v.
VITAMIN SHOPPE, INC., Defendant.

          Erica C. Mirabella MIRABELLA LAW, LLC Nick Suciu III BARBAT, MANSOUR & SUCIU PLLC Charles E. Schaffer LEVIN SEDRAN & BERMAN Charles J. LaDuca Beatrice Yakubu Cuneo Gilbert & LaDuca, LLP Attorneys for Plaintiff Richard Ferrari

          Andrea C. Kramer Julie A. Frohlich KRAMER FROHLICH LLC Michael R. McDonald Caroline E. Oks GIBBONS P.C. Attorneys for Defendant Vitamin Shoppe, Inc.

          STIPULATED PROTECTIVE ORDER

          HON. GEORGE A. O'TOOLE, U.S.D.J.

         1. Any party to this litigation and any third-party shall have the right to designate as “Confidential” and subject to this Order any information, document, or thing, or portion of any document or thing: (a) that contains trade secrets, competitively sensitive technical, marketing, financial, sales or other confidential business information, or (b) that contains private or confidential personal information, or (c) that contains information received in confidence from third parties, or (d) which the producing party otherwise believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure and Local Civil Rule 7.2. Any party to this litigation or any third party covered by this Order, who produces or discloses any Confidential material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: “CONFIDENTIAL” or “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” (hereinafter “Confidential”).

         2. Any party to this litigation and any third-party shall have the right to designate as “Attorneys' Eyes Only” and subject to this Order any information, document, or thing, or portion of any document or thing that contains highly sensitive business or personal information, the disclosure of which is highly likely to cause significant harm to an individual or to the business or competitive position of the designating party. Any party to this litigation or any third party who is covered by this Order, who produces or discloses any Attorneys' Eyes Only material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: “ATTORNEYS' EYES ONLY” or “ATTORNEYS' EYES ONLY - SUBJECT TO PROTECTIVE ORDER” (hereinafter “Attorneys' Eyes Only”).

         3. All Confidential material shall be used by the receiving party solely for purposes of the prosecution or defense of this action, shall not be used by the receiving party for any business, commercial, competitive, personal or other purpose, and shall not be disclosed by the receiving party to anyone other than those set forth in Paragraph 4, unless and until the restrictions herein are removed either by written agreement of counsel for the parties, or by Order of the Court. It is, however, understood that counsel for a party may give advice and opinions to his or her client solely relating to the above-captioned action based on his or her evaluation of Confidential material, provided that such advice and opinions shall not reveal the content of such Confidential material except by prior written agreement of counsel for the parties, or by Order of the Court.

         4. Confidential material and the contents of Confidential material may be disclosed only to the following individuals under the following conditions:

(a) Outside counsel and the administrative staff of outside counsel's firms and relevant in-house counsel for the parties;
(b) Any party to this action who is an individual, and every employee, director, officer, or manager of any party to this action who is not an individual, but as to both only to the extent necessary to further the interest of the parties in this litigation, and only after executing a written consent to be bound by the terms of Protective Order in the form attached as Exhibit A.
(c) Independent consultants or Expert witnesses, and the administrative for the independent consultants or expert witnesses, retained by outside counsel for purposes of this action, provided they have signed a non-disclosure agreement in the form attached hereto as Exhibit A;
(d) Secretarial, paralegal, clerical, duplicating and data processing personnel of the foregoing;
(e) The Court and court personnel, including but not limited to, stenographic reporters;
(f) Any court reporter or videographer reporting a deposition;
(g) The author(s) and/or original recipient (s) of a document, provided that such persons may not retain copies of the designated material unless permitted by other ...

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