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Lando & Anastasi, LLP v. Hercules Capital, Inc.

United States District Court, D. Massachusetts

August 16, 2019

LANDO & ANASTASI, LLP, Plaintiff,
v.
HERCULES CAPITAL, INC., Defendant.

          CONFIDENTIALITY AGREEMENT AND ORDER

          Honorable Dennis Saylor, IV, U.S.D.J.

         IT IS HEREBY ORDERED, that the following provisions of this Confidentiality Agreement and Order (the "Order") shall govern disclosure and use by the parties of all documents, testimony, exhibits, interrogatory answers, responses to requests to admit and any other materials and information disclosed or provided in the above-referenced action (the "Action").

         1. All Information produced or disclosed in the Action shall be used solely for the prosecution or defense (including any appeal therefrom) of the Action, and shall not be used for any other purpose.

         2. When used in this Order, the term:

(a) "Confidential Information" shall mean all documents and testimony, and all information contained therein, containing:
(i) trade secrets or other confidential research, development, financial, proprietary, or commercial information that may be subject to a protective order under FRCP 26(c)(1)(G);
(ii) private, confidential, or non-public personal information that is protected from disclosure by statute, regulation or otherwise;
(iii) information received in confidence from third parties; or
(iv) information to which the producing party otherwise believes in good faith to be entitled to protection under the terms of this Order.
(b) "Disclosing Party" shall refer to any party to this Action and any non-party disclosing or producing Confidential Information in connection with this Action.
(c) "Discovery Material" shall refer to all items or information that are produced or generated in disclosures or responses to discovery in this Action, regardless of the medium or manner in which it was stored, generated, or maintained.
(d) "Document" shall have the same meaning as provided in Rule 34 of the Federal Rules of Civil Procedure, and shall include, without limitation, all original, written, recorded, electronic, or graphic materials, and all copies, duplicates or abstracts thereof including, but not limited to, notes on documents including information contained therein or derived therefrom.
(e) "Information" shall include individual documents and records (including associated metadata) whether on paper, film or other media, as discrete files stored electronically, optically, or magnetically, or as a record within a database, archive, or container file, including emails, messages, word processed documents, digital presentations, spreadsheets, and database content.
(f) "Receiving Party" shall refer to any party to this Action and any non-party that receives Confidential Information.

         3. A Disclosing Party's designation of Discovery Material as Confidential Information constitutes a representation that such Discovery Material has been reviewed by counsel and that there is a good faith basis for such designation.

         4. Unless otherwise ordered by the court or permitted in writing by the Disclosing Party, a Receiving Party may disclose Confidential Information only to:

(a) counsel of record in this Action, as well as counsel's employees to whom it is reasonably necessary to disclose the information in connection with this Action;
(b) the named parties including in-house counsel, officers, directors, and employees of the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) experts, consultants, or investigators including their staff who have signed the Acknowledgment attached hereto as Exhibit 1;
(d) outside photocopying, microfilming, or database service providers, trial support firms, graphic production services, litigation support services, and translators engaged by the parties during this Action to whom disclosure is reasonably necessary for this Action;
(e) the court, any court to which a party petitions for discovery of a non-party, any appellate court, necessary court personnel, and jurors;
(f) court reporters and their staff, stenographers or video operators, professional jury or trial consultants, mock jurors, and professional vendors to whom disclosure is reasonably necessary for this Action;
(g) during their depositions and deposition preparation, witnesses in the Action to whom disclosure is reasonably necessary and who have signed the Acknowledgment attached hereto as Exhibit 1 (although such ...

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