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Andrews v. JCG Foods of Georgia, LLC

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

May 2, 2018

CHERRY ANDREWS, Plaintiff
v.
JCG FOODS OF GEORGIA, LLC D/B/A KOCH FOODS, Defendant.

          Douglas R. Kertscher HILL, KERTSCHER & WHARTON, LLP Attorney for Plaintiff.

          Janell M. Ahnert, Esq. BRESSLER, AMERY & ROSS, PC Attorney for Defendant Koch Foods of Pine Mountain Valley, LLC

          CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          HON. CLAY D. LAND, CHIEF U.S. DISTRICT JUDGE

         The parties hereto having consented through their respective attorneys to the entry of this Confidentiality Agreement and Protective Order in order to protect the confidentiality of certain information and to facilitate discovery, IT IS HEREBY ORDERED THAT:

         The following provisions shall govern the pretrial disclosure and use by the parties of all documents, electronically stored information, testimony, and other information given during the course of discovery that a party in good faith contends is kept as confidential or as a trade secret.

         1. The parties acknowledge that they will be exchanging documents and information solely because they are parties to the above-captioned proceeding and during the course of anticipated litigation and thus agree that all information exchanged between them will be used only for purposes of this litigation between the parties hereto and for no other purpose.

         2. The parties also acknowledge that it is possible they will produce and/or otherwise disclose in this litigation information that is confidential or proprietary.

         3. “Information” is defined broadly to include information in any form, whether provided in response to a request for information, in documents, in settlement discussions, or in testimony. “Document” is defined broadly to include tangible paper as well as information stored electronically on disc, tape, or otherwise.

         4. Counsel for any party can designate confidential or proprietary information that is a) not in the public domain and b) if that that a party in good faith contends that the information is kept as confidential or as a trade secret. The party may so designate such information as “confidential” by marking each page as such, in which event such information shall be treated as follows:

(a) Confidential information may not be shown or disclosed to any person other than: (i) counsel to a party, including paralegals, secretaries and support personnel working for that attorney on this litigation; (ii) a party to the litigation, including immediate family members and those employed by the party who are involved in the facts underlying the litigation or involved in the prosecution or defense of the litigation and who counsel to the party believes should have access to the information, provided that such persons understand the need to maintain the confidentiality of the information; (iii) experts retained by or on behalf of the party, provided such expert agrees to abide by the terms of this confidentiality agreement and order as evidenced by his or her signature on the form annexed hereto as Exhibit A; (iv) arbitrators, judges, court reporters, jurors, and employees of the arbitrator who are participating in the hearing of this litigation; and (v) witnesses who are expected to testify during the litigation or hearing of this case or any related litigation between the parties hereto, and any potential witnesses to the extent necessary to interview, prepare the witness for testimony, or question the witness, provided that such witnesses or potential witnesses who are not employees of a party to this litigation agree to abide by the terms of this confidentiality agreement as evidenced by his or her signature on the form annexed hereto as Exhibit A.
(b) After the conclusion of the litigation or any related litigation between the parties, all confidential information that is in physical tangible form shall be destroyed or returned to the party designating the information as confidential.

         5. Any party that in good faith contends the information sought is kept as confidential or as a trade secret can designate information produced in the litigation as “confidential.” The party shall do so in the following manner:

(a) If the information is a document and is produced by the party seeking to designate the information as confidential, the party shall mark the document as confidential on the face of the document. The parties shall not make mass or indiscriminate confidentiality designations. If the information is in a document produced by someone other than the party seeking to designate the document as confidential, the party seeking to designate the information as confidential shall notify the other parties to the litigation in writing that it considers the information confidential and the adverse parties receiving the information shall thereafter treat the information as confidential and shall take the steps it deems reasonably necessary to ensure that others who have received the information treat it as confidential.
(b) If the information is contained in a response to a request for information or other interrogatory by the party seeking confidential treatment, the party shall designate the response as confidential when responding to the request. If the information is contained in a response by someone other than the party seeking confidential treatment, the party seeking to designate the information as confidential shall notify the other parties to the litigation in writing within seven (7) days of said response that it considers the information confidential, and the adverse party receiving the information shall thereafter treat the ...

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