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Safe Harbor Marinas LLC v. Safe Harbor Development LLC

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

May 13, 2019

SAFE HARBOR MARINAS, LLC, Plaintiff,
v.
SAFE HARBOR DEVELOPMENT, LLC, Defendant.

          David J. Stewart Counsel for Plaintiff SAFE HARBOR MARINAS LLC

          John G. Perry Counsel for Defendant SAFE HARBOR DEVELOPMENT LLC

          PROTECTIVE ORDER OF CONFIDENTIALITY

          MARC T. TREADWELL, JUDGE UNITED STATES DISTRICT COURT

         WHEREAS, Plaintiff Safe Harbor Marinas, LLC, (hereinafter, “Plaintiff” or “SHM”), and Defendant Safe Harbor Development, LLC, (hereinafter, “Defendant” or “SHD”), collectively referred to herein as, “the Parties”, by and through their undersigned respective counsel, have jointly stipulated to the following protective order; and

         WHEREAS, the Parties anticipate that they will make available in discovery certain information of a confidential nature; and

         WHEREAS, the Parties have agreed that the following restrictions shall apply to such information;

         IT IS THEREFORE ORDERED, pursuant to Fed.R.Civ.P. 26(c), the following Protective Order is entered by the Court.

         Proceedings and Information Governed

         1. This Protective Order and any amendments or modifications hereto (“Protective Order”) shall govern any document, information or other thing furnished by any party, to any other party, and includes non-parties who receive a subpoena in connection with this action. The information protected includes, but is not limited to, answers to interrogatories, answers to requests for admission, responses to requests for production of documents, deposition testimony, transcripts and videotapes, deposition exhibits, and other writings or things produced, given or filed in this action that are designated by a party as “Confidential”, (or similarly “Confidential Information”) or “Highly Confidential/Attorneys' Eyes Only”, (or, similarly, “Highly Confidential” and/or “Attorneys' Eyes Only”), in accordance with the terms of this Protective Order, as well as to any copies, excerpts, abstracts, analyses, summaries, descriptions, or other forms of recorded information containing, reflecting, or disclosing such information. Nothing in this Protective Order shall prevent disclosure beyond the terms of this Protective Order if any document, information or thing is not designated as "Confidential" or "Highly Confidential/Attorneys' Eyes Only," if a document, information or thing is so designated but the designating party consents in writing to such disclosure, or if the Court allows such disclosure.

         Designation and Maintenance of Information

         2. For purposes of this Protective Order, 1) the “Confidential” designation shall mean that, based on a good faith belief, the document is comprised of trade secrets or commercial information which is not publicly known and is of technical or commercial advantage to its possessor, in accordance with Fed.R.Civ.P. 26(c)(7), and 2) the “Highly Confidential/Attorneys' Eyes Only” designation shall mean that, based on a good faith belief, the document is comprised of information that the producing party deems especially sensitive, which may include, but is not limited to, confidential research and development, financial information, technical information, marketing information, customer lists, any other sensitive trade secret information, or information capable of being utilized for the preparation or prosecution of a patent application dealing with such subject matter or other information required by law or agreement to be kept confidential.

         3. Non-Confidential Material - No. party shall designate publicly available documents or information as being “Confidential” or “Attorneys' Eyes Only.” Further, this Protective Order shall not be construed: (a) to prevent any party or its attorneys from making use of information which was lawfully in its possession prior to its disclosure by the producing party; (b) to apply to information which appears in public records, printed publications or otherwise becomes publicly known; (c) to apply to information which any party or its attorneys has, after disclosure by the producing party, lawfully obtained from a third party having the right to disclose such information; or (d) to apply to information which any party independently and lawfully develops.

         4. Documents and things produced during the course of this litigation within the scope of paragraph 2, subpart 1) above, may be designated by the producing party as containing Confidential information by placing on each page and each thing a legend substantially as follows: “CONFIDENTIAL.” Documents and things produced during the course of this litigation within the scope of paragraph 2, subpart 2) above may be designated by the producing party as containing Highly Confidential/Attorneys' Eyes Only information by placing on each page and each thing a legend substantially as follows: “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” or, simply, “ATTORNEYS' EYES ONLY.” Wherever practicable, the designation of documents and things as being “Confidential” or “Attorneys' Eyes Only” shall be made prior to, or contemporaneously with, the production or disclosure of such documents and things.

         5. In the case of electronically stored documents and things produced in native format, a party shall designate Confidential Information or Highly Confidential/Attorneys' Eyes Only information by including “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS' EYES ONLY” or, simply, “ATTORNEYS' EYES ONLY” in the file or directory name, or by affixing the legend “CONFIDENTIAL” or “HIGHLYCONFIDENTIAL - ATTORNEYS' EYES ONLY” or, simply, ...


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