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Equal Employment Opportunity Commission v. Exide Technologies, Inc.

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

June 19, 2019

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff,
v.
EXIDE TECHNOLOGIES, INC. Defendant.

          Robyn M. Flegal Robyn M. Flegal Equal Employment Opportunity Commission Attorney for Plaintiff Jason R. Carruthers (w/e/p by Robyn M. Flegal)

          John Wymer Jason R. Carruthers THOMPSON HINE LLP Two Alliance Center Counsel for Defendant

          CONSENT PROTECTIVE ORDER

          CLAY D. LAND CHIEF JUDGE.

         Plaintiff Equal Employment Opportunity Commission (“Plaintiff” or “EEOC”) and Defendant Exide Technologies, Inc. (“Defendant” or “Exide”) (collectively, “the Parties”), stipulate and agree through their respective counsel, subject to approval of the Court, as follows:

         1. The Parties agree that certain documents and information produced or disclosed during this litigation should be treated as “confidential, ” in order to prevent injury to the Parties or others through disclosure to persons other than those persons involved in the prosecution or defense of this litigation.

         2. “Confidential” shall mean: (1) personal or private information which would otherwise be protected from disclosure by any regulation or statute, (2) business information of a confidential or proprietary nature, (3) information that would cause unreasonable annoyance, embarrassment or oppression, by way of example, but not limitation, discovery materials such as internal business records, medical records, employee personnel files, non- public internal financial records; and (4) documents or information designated “confidential” by the Parties, as defined or described in Paragraph 3 below.

         3. Designating Documents as confidential. Any party to this litigation may in good faith designate as “confidential” any discovery materials by (a) stamping or labeling the document with the word “confidential, ” or (b) advising the opposing party in writing at the time of production that certain documents are “confidential.”

         4. Documents or Information designated as “confidential” may be disclosed, shown, or made available to the following persons:

a. the Court and Court personnel, subject to Paragraph 9 of this Order;
b. attorneys for the Parties to this litigation, including in-house attorneys for the Parties, and including persons working in secretarial, clerical, and paralegal capacities, who are providing assistance to counsel in this action;
c. qualified persons taking testimony involving confidential information or documents, including the necessary stenographic, videographic, and clerical personnel thereof;
d. consultants or experts and their staff who are employed for the purposes of this litigation, provided that they shall be given a copy of this Order and shall acknowledge in writing that they have read the Order and agree to be bound by its terms; and
e. witnesses deposed in this action or who are called as witnesses at any hearing in this action, subject to paragraph 5 of this Order.

         5. Designating Deposition Testimony as confidential. Any party may designate deposition testimony as confidential by advising counsel of record in writing within thirty (30) days of receipt of a copy of the transcript, or within such other time period mutually agreed-upon by the Parties. Such designation(s) must specify the pages of the transcript and/or the number of the exhibits being designated as confidential. Alternatively, any party may, on the record at the deposition, designate deposition testimony as confidential, by advising all persons present at the deposition that the information is confidential and subject to this Order. If such a designation is made at a deposition, all persons present who are not parties to this action shall ...


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