STIPULATED PROTECTIVE ORDER

GEORGE CARAM STEEH, District Judge.

The parties agreeing to the terms of this Order and the Court being fully advised in the premises,

1. The purpose of this Order is to facilitate exchange of financial information deemed necessary to assist in the resolution of the dispute between the parties.

2. Any financial information ("Information") disclosed or produced by a party in response to any request in connection with settlement.

3. Documents relating to Information produced in response to any request in this proceeding, including any copies, notes, or summaries thereof, shall be maintained in confidence by counsel of record for the parties to this action, to whom such materials are produced or disclosed, and shall not be further disclosed to any person or entity except the parties and their counsel, the mediator, any experts or consultants retained by the parties or their counsel to assist in evaluating the financial information.

4. All persons authorized by this Order to receive Information designated as confidential shall maintain such information strictly in accordance with this Order, and shall use such information solely for the purpose described above. No documents or information governed by this Order shall be disseminated or used for any other purpose. The Patties agree that intentional violation of these provisions, including but not limited to use of information produced under this order for business purposes, will result in monetary damages equal to an amount of the damages caused by such use or disclosure.

5. Any party or person responsible for making copies of Information governed by this Order must ensure that the copies adequately reflect the designation of confidentiality.

6. All persons authorized to receive Information under this Order (other than counsel of record) shall be shown a copy of this Order. Counsel of record for the respective parties shall ensure that all such individuals agree to comply with this Order.

7. Nothing in this Order shall prevent a party from using or disclosing its own information and documents to any person for any purpose, and any such use disclosure shall not be deemed a waiver of its rights or obligations under this Order.

8. Any party shall have the right to request financial information by formal discovery under F. R. Civ. P. 26 et. seq. All objections to any such requests are preserved.

9. The entry of this Protective Order shall not in any way detract from or constitute a waiver of the right of any party or non-party to object to the production of discovery materials or to the admissibility of any document on grounds other than confidentiality.