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Smith v. Savannah Schools Federal Credit Union

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

November 29, 2018

RICHARD SMITH AND RICKY EDGERLY, Plaintiffs,
v.
SAVANNAH SCHOOLS FEDERAL CREDIT UNION, PATRICIA HARRIS, ANGIE LEWIS, ULYSSES BRYANT, CHADASI BETTERSON Defendants.

          Catherine M. Bowman, Esq.Georgia Bar No. 494740 The Bowman Law OfficeAttorneys for Plaintiff Tracie Johnson Maurer Georgia Bar No. 395670 JACKSON LEWIS P.C. Jennifer Shoaf Richardson Georgia Bar No. 411723 JACKSON LEWIS P.C. Attorneys for Defendant

          JOINT STIPULATION AND ORDER OF CONFIDENTIALITY

          UNITED STATES MAGISTRATE JUDGE SOUTHERN DISTRICT OF GEORGIA

         Comes now Plaintiffs Richard Smith and Ricky Edgerly, and Defendants Savannah Schools Federal Credit Union, Patricia Hams, Angie Lewis, Ulysses Bryant, and Chadasi Betterson (collectively "The Parties").

         WHEREAS documents and information have been and will be supplied by some or all of the The Parties, to the other parties in this action pursuant to informal and formal discovciy proceedings, which The Parties believe constitute either confidential personnel, proprietary, or commercial or financial information or which are otherwise confidential, a trade secret, a competitive advantage and/or of a personal nature to Defendants or to Plaintiffs (hereinafter referred to collectively as "confidential materials1'), it is hereby stipulated and agreed between Defendants and Plaintiffs, through their respective attorneys, as follows:

         1.

         In producing documents pertaining to current or former SSFCU employees, members, Board members, any documents with pay or other sensitive employment information, including contact information, personal data, medical information or financial information may be deemed or designated CONFIDENTIAL. With regard to documents and responses to subpoenas, such designation shall be made at the time that such answers are served upon the requesting party or at the time the copies of documents are delivered to the requesting party or at the time documents are made available for the party's inspection.

         2.

         Each person to whom confidential material, or data or information obtained, derived or generated from confidential material, is disclosed or made available, including experts or consultants retained by the parties, shall first be advised of the existence and the contents of this Stipulation and shall be bound by its terms and conditions. No such person shall divulge any confidential material, or any data or information obtained, derived or generated from confidential material, to any other person, except as provided herein. This Paragraph shall not apply to deponents who during the course of a deposition are shown confidential material, or data or information obtained, derived or generated from confidential material.

         3.

         Confidential material, or data and information obtained, derived or generated from confidential material shall be disclosed only to:

(1)The Court and Court personnel;
(2) The attorneys of record in this action, persons employed in the attorneys' offices and agents of the attorneys such as copy services and litigation support services;
(3) Plaintiffs;
(4) ...

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