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Boswell v. Chipotle Mexican Grill, Inc.

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

January 16, 2020

REBECCA BOSWELL, Plaintiff,
v.
CHIPOTLE MEXICAN GRILL, INC., Defendant.

          WIGGINS, CHILDS, PANTAZIS, FISHER & GOLDFARB, LLC Kevin W. Jent, pro hac vice Alabama Bar No. 0804E61K LOBER & DOBSON, LLC William Gregory Dobson Georgia Bar No. 237770 A. Danielle McBride Georgia Bar No. 800824 Attorneys for Plaintiff Rebecca Boswell

          MARTENSON, HASBROUCK & SIMON LLP Elizabeth Bulat Turner Georgia Bar No. 558428 Hee Won Choi Georgia Bar No. 364457 Attorneys for Defendant Chipotle Mexican Grill, Inc.

          PROTECTIVE ORDER THE COURT ALERTS THE PARTIES THAT IT HAS ADDED A FINAL PARAGRAPH TO THIS PROTECTIVE ORDER THAT WAS NOT INCLUDED IN THE STIPULATED ORDER SUBMITTED TO THE COURT. CDL

          CLAY D. LAND CHIEF JUDGE

         Discovery in this case may involve production and/or review of confidential information of the parties and non-parties to this action, as well as sensitive or proprietary business information of Chipotle Mexican Grill, Inc. (“Chipotle” or “Defendant”). The parties in this action consent to entry of this Discovery Confidentiality Order in order to protect the legitimate privacy interests of the parties and non-parties alike, and to provide Plaintiff Rebecca Boswell (“Plaintiff”) and Chipotle and their respective counsel, certain documents potentially relevant to this action. Accordingly, for good cause shown, it is ORDERED as follows:

         1. Any party to this litigation and any non-parties to this action shall have the right to designate as “Confidential” and subject to this Order any information, document, or thing, or portion of any document or thing: (a) that contains trade secrets, competitively sensitive technical, marketing, financial, sales or other confidential business information; or (b) that contains private or confidential personal information; or (c) that contains information received in confidence from third parties; or (d) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or (e) personnel or employment records including those of persons not parties to the case; or (f) which the producing party otherwise believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure and Local Civil Rule 5.4. Any party to this litigation or any third party covered by this Order, who produces or discloses any Confidential material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: “CONFIDENTIAL” or “CONFIDENTIAL - SUBJECT TO DISCOVERY CONFIDENTIALITY ORDER” (hereinafter “Confidential”).

         2. Any party to this litigation and any non-parties to this action shall have the right to designate as “Attorneys' Eyes Only” and subject to this Order any information, document, or thing, or portion of any document or thing that contains highly sensitive business or personal information, the disclosure of which is highly likely to cause significant harm to an individual or to the business or competitive position of the designating party. Any party to this litigation or any third party who is covered by this Order, who produces or discloses any Attorneys' Eyes Only material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: “ATTORNEYS' EYES ONLY” or “ATTORNEYS' EYES ONLY - SUBJECT TO DISCOVERY CONFIDENTIALITY ORDER” (hereinafter “Attorneys' Eyes Only”). The Attorneys' Eyes Only designation shall be used sparingly and in good faith. For the designation to be effective, on or before the time of disclosure, the designating party must provide a separate notice of the designation in writing to the receiving party, explaining all reasons for the designation.

         3. All Confidential material shall be used by the receiving party solely for purposes this litigation, including any appeals or related arbitrations, shall not be used by the receiving party for any business, commercial, competitive, personal or other purpose, and shall not be disclosed by the receiving party to anyone other than those set forth in Paragraph 4, unless and until the restrictions herein are removed either by written agreement of counsel for the parties, or by Order of the Court. It is, however, understood that counsel for a party may give advice and opinions to his or her client solely relating to the above-captioned action based on his or her evaluation of Confidential material, provided that such advice and opinions shall not reveal the content of such Confidential material except by prior written agreement of counsel for the parties, or by Order of the Court.

         4. Confidential material and the contents of Confidential material may be disclosed only to the following individuals under the following conditions:

a. Outside counsel (herein defined as any attorney at the parties' outside law firms) and relevant in-house counsel for the parties;
b. Outside experts or consultants retained by outside counsel for purposes of this action, provided they have signed a non-disclosure agreement in the form attached hereto as Exhibit A;
c. Secretarial, paralegal, clerical, duplicating and data processing personnel of the foregoing;
d. The Court and court personnel;
e. Any deponent may be shown or examined on any information, document or thing designated Confidential if it appears that the witness authored or received a copy of it, was involved in the subject matter described therein or is employed by the party who produced the information, document or thing, or if the producing party consents to such disclosure;
f. Vendors retained by or for the parties to assist in preparing for pretrial discovery, trial and/or hearings including, but not limited to, court reporters, litigation support personnel, jury consultants, individuals to prepare demonstrative and audiovisual aids for use in the courtroom or in depositions or mock jury sessions, as well as their staff, ...

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