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Cheek v. Profit Services Group, LLC

United States District Court, S.D. Georgia, Savannah Division

June 5, 2018

DANIEL CHEEK, Plaintiff,
v.
PROFIT SERVICES GROUP, LLC, Defendant.

          COUNSEL FOR PLAINTIFFS, DANIEL CHEEK, SMITHMARCO, P.C., DAVID M. MARCO PRO HAC VICE APPLICATION PENDING

          FORTAS LAW GROUP, LLC, E. SCOTT FORTAS, GEORGIA BAR NO. 269980

          COUNSEL FOR DEFENDANT, PROFIT SERVICES GROUP, LLC, BEDARD LAW GROUP, P.C., MICHAEL K. CHAPMAN, GEOGRIA BAR NO. 322145

          STIPULATED ORDER - CONFIDENTIALITY AGREEMENT

          HON. G.R. SMITH MAGISTRATE JUDGE, UNITED STATES DISTRICT COURT

         Plaintiff, Daniel Cheek, and Defendant, Profit Services Group, LLC, have advised the Court that they anticipate discovery and production of documents which may be the proper subject of non-disclosure under Fed R. Civ. P. 26(c). In order to assist in the timely completion of discovery, the Court enters this stipulated Order governing the procedure for seeking the protections under Fed.R.Civ.P. 26(c).

         1. Confidentiality as a Basis of Non-Disclosure.

         Having provided these parties a mechanism for the protection of documents of information of a confidential nature, the parties may not assert the confidential nature or trade secret status of documents as a basis of non-disclosure except as provided in this order.

         2. Designation of Confidentiality.

         A party responding to requests for production or interrogatories may designate the responsive information to that discovery as confidential (hereafter referred to as "information designated as confidential"). That party shall make the designation by producing the information and affixing a stamp conspicuously designating the information as "CONFIDENTIAL." The party making the designation shall serve with the information a log of all information designated as confidential and identify each basis upon which the designation is made pursuant to FRCP 26(c). The failure to designate the information or provide the log waives any such designation.

         3. Protection of Information Designated as Confidential.

         Any information designated as confidential shall be protected as confidential under the terms of this Order until such time as 1) the Court rules on the designation pursuant to a motion by designating party, 2) the designating party waives the objection expressly or by failure to file a timely motion for a protective order, 3) the documents are submitted to the Court in connection with a dispositive motion, or 4) the documents are submitted at trial of this matter.

         If any information which is protected as confidential is submitted in connection with a dispositive motion or at trial pursuant to this Order, the information ceases to be protected as confidential, but any party may move to seal the Court's record and proceedings under the applicable law as provided below.

         Any information which is protected as confidential may not be used outside this case and may only be used in this litigation. Information ...


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