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Modeski v. Summit Retail Solutions, Inc.

United States District Court, D. Massachusetts

November 27, 2019

JOSEPH MODESKI, et al., Plaintiff,
v.
SUMMIT RETAIL SOLUTIONS, INC., Defendant.

          Benjamin L. Davis, III Michael A. Brown The Law Offices of Peter T. Nicholl COUNSEL FOR PLAINTIFFS

          Barry J. Miller (BBO No. 661596) Hillary J. Massey (BBO No. 669600) Seyfarth Shaw LLP COUNSEL FOR DEFENDANT

          STIPULATED CONFIDENTIALITY PROTECTIVE ORDER

         To adequately protect material entitled to be kept confidential, the parties in the above-captioned matter, by and through their respective counsel, and pursuant Rule 26(c) of the Federal Rules of Civil Procedure, hereby stipulate and agree to the terms of this Stipulated Confidentiality Protective Order as follows:

         1. Scope.

         This Stipulated Confidentiality Protective Order ("Order") shall apply to information, testimony, documents and things provided by the parties in the above-captioned matter that contain proprietary, personal or confidential information that is not generally disclosed to the public by the parties and any other information that is required by law or agreement to be kept confidential.

         2. Non-disclosure of Confidential Documents.

         No confidential document may be disclosed to any person except as provided in Paragraph 3 below. A "confidential document" means any document that bears the legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL." In the event that a party inadvertently fails to designate a document as confidential, and the party reasonably and in good faith believes that it should be so designated, the party may subsequently make such a designation by notifying the recipient's counsel in writing as soon as practicable. After receipt of such notification, the recipient will treat the information as if it had been designated confidential at the time the information was produced. The parties agree that either party may designate appropriate documents prior to the Court's entry of this Order.

         3. Permissible Disclosures.

         Documents and information stamped "CONFIDENTIAL" may be disclosed to: (i) counsel for the parties in this action who are actively engaged in the conduct of this litigation, including counsel's legal and clerical assistants; (ii) a party, or an officer, director, or employee of a corporate party deemed necessary by counsel for that party to aid in the prosecution, defense, or settlement of this action; (iii) any person designated by the Court; (iv) persons sitting for depositions or appearing as trial witnesses; (v) court reporters employed in this action; (vi) outside consultants or experts retained for the purpose of assisting counsel in the litigation; and (vii) any other person as to whom the parties in writing agree, provided, however, that persons identified in subparts (vi) and (vii) shall sign the form appended as Exhibit A prior to the disclosure of any confidential documents to such person.

         Documents and information stamped "HIGHLY CONFIDENTIAL" may not be disclosed to any person or entity, except outside or internal counsel for the parties, as well as their paralegals, investigative, secretarial and clerical personnel who are employed by and engaged in assisting such counsel in this litigation, or to the Court in accordance with this Order.

         4. Dispute Regarding Classification.

         In the event that a party objects to the designation of any document or documents as confidential by the other party, the objecting party shall provide notification of the objection to counsel for the party asserting confidentiality and may seek a Court order. Any document(s) that are stamped confidential and subject to challenge shall be treated as subject to the protections of this stipulation until the Court orders otherwise.

         5. Designation of Transcripts.

         When confidential information is incorporated into a transcript of a deposition, hearing, trial or other proceeding, including exhibits, the designating party shall, with the cooperation of all other parties, make arrangements with the reporter during the course of such deposition or other proceeding to label such transcript, portions thereof and/or exhibits as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL." In the alternative, a party may designate, in writing, such transcripts, portions thereof and/or exhibits as ...


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