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Cavallaro v. Innovative Insurance Partners, LLC

United States District Court, D. Massachusetts

October 4, 2019

CHRISTOPHER CAVALLARO, Plaintiff,
v.
INNOVATIVE INSURANCE PARTNERS, LLC, Defendant.

          CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          Richard G. Stearns United States District Judge

         This Confidentiality Agreement and Protective Order (“Protective Order”) is entered into by Plaintiff and Defendant (the “parties”) to protect from disclosure documents and information the parties deem to be confidential. The Protective Order permits parties to designate documents and information as “CONFIDENTIAL.” Documents and information so designated may only be disclosed or used as provided herein. Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby stipulated and agreed by and among the parties, through their respective counsel and subject to the approval of the 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 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 action and not for any other litigation, or for any business or other purpose whatever.

         2. Any party producing information (whether in the form of documents, testimony, interrogatory answer, or otherwise) (a “Producing Party”) 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 action, and such documents and information shall not be disclosed to any person except:

(a) counsel representing the parties to this action, and employees of their respective office and firms;
(b) parties to this action and their officers, directors, members, managers, partners, attorneys, and employees;
(c) the Court and its support personnel;
(d) a deponent or witness who has signed a statement in the form of Exhibit A hereto stating that s/he has read this Protective Order and agrees to be bound by its terms;
(e) consulting and testifying experts or other consultants retained to assist counsel of record or a party for the purpose of assisting in the prosecution, defense, or settlement of, or in the preparation for trial of, this action and who have signed a statement in the form of Exhibit A hereto stating that s/he has read this Protective Order and agrees to be bound by its terms;
(f) copying or imaging services, court reporters, videographers, non-technical consultants, graphics personnel, and translators associated with or retained by a party in connection with this action;
(g) creditors and prospective creditors of, and investors and prospective investors in, Defendant;
(h) accountants, financial advisors and tax advisors for any party, and
(i) 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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