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Moss v. General Motors, LLC

United States District Court, E.D. Arkansas, Jonesboro Division

March 11, 2016

ANDREW MOSS, Plaintiff,
v.
GENERAL MOTORS, LLC, Defendant.

STIPULATED PROTECTIVE ORDER

D. P. Marshall Jr. United States District Court Judge

This matter came before the Court on the stipulation of counsel for Plaintiff Andrew Moss ("Plaintiff) and counsel for Defendant General Motors LLC (hereinafter "GM LLC"), for the entry of an order governing the disclosure and handling of documents that defendant GM LLC considers to be confidential.

The Court, being duly advised, now ORDERS:

1. GM LLC may designate items of discovery or other information produced or disclosed to Plaintiff as being Confidential or Highly Confidential and subject to this Protective Order, which designation shall make such items and all copies, prints, summaries, or other reproductions of such information subject to this Order. All such documents or other tangible items produced by Defendant shall be clearly stamped or labeled to indicate that such material is subject to Protective Order, and testimony or other types of information based upon such documents or tangible items shall be similarly designated in clear terms.

2. GM LLC shall designate as being "Confidential" under this Protective Order only such documents and materials which it or its component or subsystem suppliers have determined in good faith to constitute or contain a trade secret, competitively sensitive information or other confidential research, development, technical or commercial information. All such documents and materials shall be clearly labeled to indicate that such material is Confidential subject to Protective Order, and testimony or other types of information based upon such documents or tangible items shall be similarly designated in clear terms.

3. GM LLC shall designate as being "Highly Confidential" under this Protective Order only three-dimensional ("3D") electronic CAD data or mathematical modeling or other materials that are so highly confidential that disclosure could cause substantial and irreparable economic harm. All such documents and materials shall be clearly labeled to indicate that such material is Highly Confidential subject to Protective Order, and testimony or other types of information based upon such documents or tangible items shall be similarly designated in clear terms.

4. Materials designated as Confidential or Highly Confidential and copies thereof may be disseminated, used, disclosed, or otherwise made available only for purposes of this litigation and only to the following persons:

a. Attorneys of record in this action and their partners or associate attorneys;
b. Any persons regularly employed by such attorneys or their firms, when working in connection with this action under the supervision of partners or associate attorneys of said firms;
c. Any independent expert or consultant specifically retained by counsel to provide assistance, expert advice, technical consultation, or testimony in this action, and the employees of such experts, consultants or similar persons when working in connection with this action under the supervision of said persons, provided that such persons have first been furnished with a copy of this Order, read it, and agree to be bound by its terms by signing the Affidavit attached as Exhibit A to this Order;
d. The Court;
e. Court reporters or other official personnel reasonably required for the preparation of transcripts or testimony;
f Mediators and other individuals appointed by the Court in this matter;
g. GM LLC's employees, either by deposition or trial testimony, who may be shown and questioned about ...

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