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Olah v. O'Reilly Automotive Stores, Inc.

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

January 30, 2019

RALF OLAH, Plaintiff,
v.
O'REILLY AUTOMOTIVE STORES, INC. d/b/a O'REILLY AUTO PARTS, Defendant.

          AGREED PROTECTIVE ORDER

          CLAY D. LAND CHIEF UNITED STATES DISTRICT JUDGE

         WHEREAS, the parties are engaged in discovery which involves, among other things, the production of information by the parties which one or both parties deem confidential, including personal, proprietary or commercial information, the parties have agreed to provide confidential information subject to the protective provisions below.

         DEFINITIONS

         A. Confidential Information:

         “Confidential Information” includes, but is not limited to: medical information regarding a party or non-party; non-public commercial or business information or documents, including company policies, practices, and procedures; financial and sales information; Social Security numbers; tax identification numbers; bank or financial institution account numbers; certain information contained in employment files of a party or non-party; and any information designated to be Confidential by a party which is produced solely for the purposes of this litigation, whether it is revealed in a document, deposition, interrogatory response or otherwise. In the event that a disagreement arises with respect to the designation of certain information as Confidential, the parties will attempt to resolve the dispute before presenting it to the Court. The non-designating party may then, however, challenge the designation by way of conference or application to the Court.

         B. Document

         means any written or graphic matter, no matter how produced, recorded, stored or reproduced and includes, without limitation, deposition transcripts, exhibits thereto, responses to discovery demands, tape recordings and electronically stored data.

         C. Qualified Persons means

         (i) the party and the party's counsel, including such counsel's associate attorneys assisting in this action; (ii) any litigation assistant, paralegal, stenographic, secretarial or clerical personnel assisting such counsel in this action; (iii) persons retained by or on behalf of the party in this action solely to assist in the preparation of this case for trial; (iv) any assistant, stenographic, secretarial or clerical personnel employed by an expert or assisting such expert in the preparation of this case for trial; (v) the Court and any court reporter or typist transcribing testimony; and (vi) any other persons agreed to in writing by the parties.

         TERMS AND CONDITIONS REGARDING PRODUCTION, ACCEPTANCE AND DISSEMINATION OF CONFIDENTIAL INFORMATION

         1. Only Qualified Persons may have access to Confidential Information.

         2. Qualified Persons shall use Confidential Information solely for the purposes of this action and shall not disclose any Confidential Information to anyone other than a Qualified Person who has complied with the requirements of Paragraph 3 below.

         3. Prior to the receipt of Confidential Information, all Qualified Persons, except those identified in Paragraph C (i), (ii), and (v), shall have read this Order and agree to be bound by its terms, and acknowledge that Confidential Information is to be used solely for the purposes of this action and must not be disclosed except as provided this Order. All Qualified Persons further agree to not make any copies of the Confidential Information and keep any Confidential Information in their personal custody until they have completed their assigned duties regarding such information. As soon as such duties are completed, Qualified Persons shall return the Confidential Information to the party's counsel who provided it. Qualified Persons acknowledge that that violation of the terms of this Order may be regarded as contempt of court.

         4. If a party intends to file with the Court or offer in evidence at trial or in any other proceedings in open court any document(s) containing Confidential Information, the party ...


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