Filed: Apr. 03, 2015
Latest Update: Apr. 03, 2015
Summary: STIPULATED PROTECTIVE ORDER CRAIG B. SHAFFER , Magistrate Judge . The Parties, Plaintiff Hsia Fang Sung and Defendant DSS Uniter, LLC ("Dillard's"), through their respective counsel, hereby stipulate and agree as follows: During the course of the above captioned lawsuit ("Lawsuit"), Dillard's has identified portions of its store security footage ("Confidential" materials) that are relevant to the Parties' claims and defenses, which constitute private, confidential, or commercial informatio
Summary: STIPULATED PROTECTIVE ORDER CRAIG B. SHAFFER , Magistrate Judge . The Parties, Plaintiff Hsia Fang Sung and Defendant DSS Uniter, LLC ("Dillard's"), through their respective counsel, hereby stipulate and agree as follows: During the course of the above captioned lawsuit ("Lawsuit"), Dillard's has identified portions of its store security footage ("Confidential" materials) that are relevant to the Parties' claims and defenses, which constitute private, confidential, or commercial information..
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STIPULATED PROTECTIVE ORDER
CRAIG B. SHAFFER, Magistrate Judge.
The Parties, Plaintiff Hsia Fang Sung and Defendant DSS Uniter, LLC ("Dillard's"), through their respective counsel, hereby stipulate and agree as follows:
During the course of the above captioned lawsuit ("Lawsuit"), Dillard's has identified portions of its store security footage ("Confidential" materials) that are relevant to the Parties' claims and defenses, which constitute private, confidential, or commercial information, within the meaning of Federal Rule of Civil Procedure 26(c). In order to expedite the flow of discovery materials, the parties have submitted this Stipulated Protective Order. Accordingly, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and at the request of counsel for the parties, the Court enters the following Order:
1. With respect to the "Confidential" materials, Dillard's may designate this material as "Confidential" by either conspicuous stamping on the medium holding the information (e.g., the CD), or by express written notice to Plaintiff.
2. "Confidential" materials shall not be used or disclosed for any purpose except the preparation and trial of this Lawsuit, and "Confidential" materials shall not be disclosed to anyone except as expressly set forth herein.
3. "Confidential" materials shall (1) only be used in the Lawsuit and/or any appeal of this Action; and (2) be maintained in confidence by the plaintiff and not disclosed by the plaintiff except to persons entitled to access thereto pursuant to Paragraph 4 below.
4. "Confidential" materials shall not, without consent of Dillard's or further Order of the Court, be disclosed except that such information may be disclosed to:
a. Attorneys actively working on this case;
b. Persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by said attorneys in the preparation of trial, at trial, or at other proceedings in this case;
c. Representatives of the party who have a need to know the content of the document; each such party representative shall execute the written acknowledgement called for in paragraph 4 below;
d. Expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
e. The Court and its employees;
f. Stenographic reporters who are engaged in this action;
g. Deponents, witnesses, or potential witnesses;
h. Any mediator or other person assigned for the purposes of Alternative Dispute Resolution and their staff; and
i. Other persons by written agreement of the parties.
5. Upon final determination of the Lawsuit, "Confidential" materials shall be handled subject to the regular business practices for maintenance and destruction of client files by the Parties' counsel.
