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Haskett v. T.N.H.D Partners LLC

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

April 12, 2017

ROBERT HASKETT AND LAURA HASKETT PLAINTIFFS
v.
T.N.H.D PARTNERS, LLC d/b/a HARLEY DAVIDSON OF COOL SPRINGS; 4162DOERR ROAD, INC. D/B/A MARSHALL DISTRIBUTING, INC.; WESTERN POWER SPORTS, INC., as successor of MARSHALL DISTRIBUTING, INC.; POWER PRIME LIMITED; And JOHN DOE 1, UNKNOWN DEFENDANT DEFENDANTS

          PROTECTIVE ORDER

         The parties to the above-referenced proceeding have requested that a Protective Order be entered, and good cause appearing therefore, it is so ordered by the Court as follows:

         1. The term "Discovery Materials" shall be deemed to mean produced documents, responses to interrogatories and requests for admissions, deposition or other testimony, and any other information, document(s) or object(s) which have been or will be disclosed, produced or received by any party during prehearing proceedings in this action. All Discovery Materials produced during this action shall be used only for the prosecution or defense of this action and shall not be used for any business or competitive purpose or any other purpose whatsoever.

         2. The term "Protected Information" shall be deemed to refer to all Discovery Materials designated by any party or non-party as either "Confidential" or "Highly Confidential - Attorneys' Eyes Only" during the course of discovery in this case, as set forth below.

         3, The following shall govern as to all "Protected Information."

         (a) Any party or non-party who produces or provides Discovery Materials (a "producing party") may designate as "Confidential" any Discovery Material that the producing party believes in good faith constitute or disclose information that qualifies for protection pursuant to Federal Rule of Civil Procedure 26(c) including, but not limited to, information that is a trade secret or other confidential research, development, commercial, or financial information.

         (b) Confidential material may be further designated as "Highly Confidential -Attorneys' Eyes Only" by a producing party if that producing party believes in good faith that the material contains or discloses information that would, if disclosed to a competitor or to any entity with whom the producing party engages in commercial activity, either (i) reveal significant proprietary technical or business information of or held by the producing party, (ii) cause substantial economic harm to the competitive position of the producing party or (iii) put any person receiving such information at an unfair competitive advantage.

         (c) A producing party may designate written Discovery Materials as Protected Information by causing each document that contains such information to be stamped or labeled "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL -ATTORNEYS' EYES ONLY, " as applicable.

         (d) With respect to depositions or other testimony, a party or witness may, by statement on the record or by other agreement of counsel, designate any portion of testimony as Protected Information. (Any party or witness present who is allowed by this Order to receive the Protected Information, as designated, may remain present during the scope of questioning with regard to subjects so designated, while all other persons shall be excused until questioning regarding non-Protected Information has resumed.) In addition, the party or witness may, by letter to all counsel of record, designate any portion of the testimony as Protected Information at any time up to thirty (30) days after actual receipt of the final transcript of the testimony. Until the end of the thirty-day period (or until an earlier designation is made by counsel), the entire testimony shall be treated as Highly-Confidential - Attorneys' Eyes Only.

         (e) Material designed Highly Confidential - Attorneys' Eyes Only shall not be disclosed directly or indirectly, in whole or in part, in words or substance, except during the course of this case and then only to and among the following persons:

1. The outside and in-house attorneys for the receiving party directly involved in this lawsuit, and those attorneys' employees working under their direct supervision;
2. Any person retained by any attorney described in subparagraph (e)(1) above, to assist as an independent consulting or testifying expert in the preparation of this action for trial who is neither employed by a party nor a competitor of the producing party (if there is any question about whether or not an expert is a competitor of or is employed by a competitor of the producing party, no material designated Highly-Confidential -Attorneys' Eyes Only shall be provided to the expert before (a) the person desiring to do so has notified the producing party of the expert and the designated material involved, (b) the producing party has been given at least ten days within which to object, and (c) in the event that the producing party does object, that objection has been overruled by the Court.);
3. Court officials involved in this litigation (including court reporters and person operating video recording equipment at depositions), provided that the parties and any other person subject to the provisions of this Order shall comply with the provisions governing the sealing of materials set forth below; and
4. Any person who authored or received such information or documents in the ordinary course of the business of his or her employer.

         (f) Material designated Confidential, but not Highly-Confidential -Attorneys' Eyes Only shall not be disclosed, directly or indirectly, in whole or in part, in words or substance, except during the course ...


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