Filed: Mar. 27, 2019
Latest Update: Mar. 27, 2019
Summary: STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS NANCY J. KOPPE , Magistrate Judge . The parties hereby stipulate and agree as follows: WHEREAS, the parties, by and through their attorneys, have requested the inspection, copying, and/or production of certain documents and materials containing proprietary and competitively-sensitive business information constituting confidential commercial information covered by Fed. R. Civ. P. 26(c)(1)(G); and WHEREAS, Thor Motor Coach, I
Summary: STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS NANCY J. KOPPE , Magistrate Judge . The parties hereby stipulate and agree as follows: WHEREAS, the parties, by and through their attorneys, have requested the inspection, copying, and/or production of certain documents and materials containing proprietary and competitively-sensitive business information constituting confidential commercial information covered by Fed. R. Civ. P. 26(c)(1)(G); and WHEREAS, Thor Motor Coach, In..
More
STIPULATION FOR PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS
NANCY J. KOPPE, Magistrate Judge.
The parties hereby stipulate and agree as follows:
WHEREAS, the parties, by and through their attorneys, have requested the inspection, copying, and/or production of certain documents and materials containing proprietary and competitively-sensitive business information constituting confidential commercial information covered by Fed. R. Civ. P. 26(c)(1)(G); and
WHEREAS, Thor Motor Coach, Inc. (TMC) requires that the confidentiality of the documents and/or materials, and the information contained in the documents and materials, be maintained; and
WHEREAS, the parties and their attorneys have agreed to comply with the letter and intent of that confidentiality:
IT IS HEREBY STIPULATED THAT:
The parties and their attorneys shall not give, show, or otherwise directly or indirectly disclose any such documents and/or materials identified as "Confidential," or the substance thereof, or any copies, prints, negatives, or summaries thereof, to any entity or person except the parties and their attorneys and any agents, experts, consultants, other persons employed by the parties, witnesses, potential witnesses, court reporters or court personnel in connection with and solely for this action. Any person retaining the documents and/or materials identified as "Confidential" shall review the Protective Order entered pursuant to this Stipulation, agree to abide by the Protective Order, and acknowledge in writing his or her agreement to abide by the Protective Order.
Within 14 days after the conclusion of this litigation by settlement, judgment, appeal, or otherwise, the parties and their attorneys shall, upon written request by TMC, either (1) return to TMC, all documents and copies of all documents identified as "Confidential"; or (2) destroy all documents and copies of all documents identified as "Confidential" and certify in writing that destruction.
To be deemed "Confidential," the documents and/or materials must be so marked by TMC, or specified in the record.
The Court may amend this order as is appropriate.
This Order shall not be amended except on prior written notice to counsel.
IT IS SO STIPULATED.
IT IS SO ORDERED.
