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Cooper v. Parker Promotions, Inc

United States District Court, M.D. Georgia, Columbus Division

May 2, 2018

ROBERT COOPER, et al., Plaintiff,
v.
PARKER PROMOTIONS, INC., et al., Defendants.

          David R. Helmick Georgia Bar No. 344210 C. Morris Mullin Georgia Bar No. 528550 Waldrep, Mullin & Callahan, LLC Facsimile: 706-320-0600 Attorneys for Defendants

          Michael A. Caldwell Georgia Bar No. 080791 Charles R. Bridgers Georgia Bar No. 080791 Matthew W. Herrington Georgia Bar No. 275411 Delong, Caldwell, Bridgers & Fitzpatrick, LLC Attorneys for Plaintiffs

          CONSENT PROTECTIVE ORDER

          CLAY D. LAND, CHIEF DISTRICT COURT JUDGE

         1. This cause comes before the Court pursuant to the agreement of the Plaintiffs Robert Cooper, Amalizz Matthews, Whitney S. Dowdell, Lakiesha Goodine and Kira Sykes (“Plaintiffs”), and Defendants Parker Promotions, Inc. and Nicholas Parker (“Defendants”).

         2. This Order shall govern the use, handling and disclosure of all documents and responses to interrogatories exchanged in this action that are designated to be subject to this Order in accordance with the terms hereof.

         3. Personnel files and any other documents maintained by Defendant Parker Promotions, Inc. concerning individual employees and Defendants' confidential business matters, including Defendant Parker Promotions' personnel information, and proprietary, classified and/or trade secret or confidential information, may be designated as “Confidential.” Further, all non-public business, medical, financial, and other personal information and records of Plaintiffs may be designated as “Confidential.” “Confidential” information shall not include the name of any person disclosed by the Parties.

         4. Any party producing, providing, or filing documents, responses to interrogatories, or other materials in this action may designate such documents, responses to interrogatories or other materials and the contents therein “Confidential, ” subject to this Order, by typing or stamping on the front of the document, or on the portion(s) of the document for which confidential treatment is desired, “Confidential.” If Confidential information is provided in response to written discovery, such Confidential information shall be disclosed in an attachment marked “Confidential” so as to avoid designating the entire response as confidential. With respect to deposition testimony, a party may designate portions of deposition testimony as “Confidential” during a deposition by asking the court reporter to mark such testimony or within thirty days of receipt of the transcript. All such documents or materials designated “Confidential” shall be treated as “Confidential” pursuant to this Order unless the Court shall, on motion and for good cause shown, decide otherwise or except as otherwise provided herein. It is agreed that at the trial of this case any documents so designated and submitted to the trier of fact shall not bear the stamped designation “Confidential.”

         5. Either party may challenge the confidentiality designation of any documents, responses to interrogatories, portions of depositions, or other material under this protective order no later than the close of discovery or within ten (10) days of receipt of the document, whichever last occurs.

         6. Except as provided herein, all material designated “Confidential” pursuant to this Order shall not be used directly or indirectly by any person for any reason or purpose whatsoever other than for the prosecution of the parties' claims and defenses in these actions. Upon receiving any documents, responses to interrogatories or other materials designated “Confidential” pursuant to this Order or receiving deposition testimony designated as “Confidential” pursuant to this Order, counsel for the parties hereby agree not to disclose in any manner whatsoever such documents, responses to interrogatories (including copies thereof) or other materials, or the subject, existence or contents of said documents, to any person not acting and participating as an attorney of record (or staff of such attorney assisting the attorney in this action) in these actions, subject only to the exceptions outlined in the following paragraph. In addition, all persons to whom “Confidential” documents, responses to interrogatories, and/or other materials are disclosed, are hereby enjoined from disclosing such documents, responses to interrogatories, and/or materials to any person except as provided in this Order.

         7. The following exceptions to the restrictions set forth above shall be recognized, agreed to, and followed:

(a) “Confidential” material under this Order may be disclosed to the parties in the course of their participation in the present litigation. The parties agree that they will at all times abide by the terms of this Order and maintain the confidentiality of such materials and will not disclose in any manner whatsoever either the documents themselves, copies thereof or the contents of any “Confidential” material to anyone other than his, her or its counsel or a member of that counsel's staff.
(b) The parties' counsel may disclose “Confidential” material to any person working with counsel in the prosecution or defense of this action. Such disclosures will occur only on the condition that any such person understands fully the confidentiality of the information and the restrictions regarding its disclosure as imposed by this Order and agrees to comply with such restrictions.
(c) Counsel may disclose material designated as “Confidential” to any witness or prospective witness during discovery or in preparation for trial, or at trial, as needed to prepare such witness or prospective witness for such trial or pre-trial testimony. Disclosure of “Confidential” material may also be made to the extent necessary to examine or cross-examine witnesses during pre-trial depositions or to the extent needed to support or oppose any motion to the Court, or with respect to any appeal.
(d) Counsel may disclose “Confidential” material to any expert or to any person who will or may provide expert testimony and/or who may submit an expert affidavit or declaration at any stage of these proceedings, including discovery, trial, and any appeal, provided that such expert agrees to be bound by the terms of this Order, as set forth in subsection (e) below, and ...

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