Craine v. General Motors LLC

Filing 16

AGREED PROTECTIVE ORDER. Signed by Judge D. P. Marshall Jr. on 7/20/2016. (jak)

Download PDF
THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF ARKANSAS JONESBORO DIVISION DONNA J. CRAINE PLAINTIFF VS. CIVIL ACTION NO. 3:16-cv-00069 GENERAL MOTORS, LLC DEFENDANT AGREED PROTECTIVE ORDER IT IS ORDERED that General Motors LLC shall designate, in good faith, those documents which it deems to contain trade secrets and confidential research, development and commercial information (hereinafter referred to as "confidential materials") and that any such documents produced by General Motors LLC in this case shall be marked as being produced subject to a Protective Order. Plaintiff shall have the right to contest any such designation made by General Motors LLC. In addition, the following shall apply to such confidential materials produced in this case: A. These confidential materials shall not be reproduced except as necessary to prosecute this cause by Plaintiff. B. These confidential materials shall not be available for inspection by anyone, except: 1. Plaintiff in this case and her counsel; 2. General Motors LLC, its employees and its counsel in this case; 3. Experts, consultants and other persons who are assisting counsel for the Plaintiff in the preparation of this matter for trial. Before Plaintiff's counsel allows any such person to view confidential materials, Plaintiff's counsel must first obtain the signature of such person on a copy of this Order. At the conclusion of this case, Plaintiff's counsel must provide General Motors LLC with a list of all persons who signed a copy of this Order, as well as copies of the signed orders; and Exhibit 11 A" 4. Any judge and/or jury having jurisdiction in this matter. C. The substance of any information obtained from these confidential materials shall not be disseminated to anyone not authorized to examine these confidential materials. D. Pursuant to Fed.R.Civ.P. 5.2, any confidential document covered by this Protective Order shall be redacted to remove confidential information, if possible, rather than filing the document under seal. Before filing a redacted version of any confidential document covered by this Protective Order, counsel will provide the proposed redacted version of the document to opposing counsel for review and allow 3 full business days to respond as to whether it is acceptable to file the redacted version in lieu of a full version under seal. E. To the extent that there is a dispute about the whether a document is confidential, counsel shall confer in good faith in person before bringing any discovery dispute to the Court. Any dispute must be handled according to the procedure in the Court's Final Scheduling Order. F. Any notes, lists, memoranda, index or compilation prepared or based on any examination of these confidential materials shall be subject to this Protective Order and shall not be disseminated to anyone not authorized to examine these confidential materials. G. This Order shall terminate one year after the end of this litigation. H. The parties recognize that the competitive value of the information contained in the confidential materials produced by General Motors LLC will continue to be important to General Motors LLC after the expiration of this protective order. Therefore, at the conclusion of this case, all confidential materials shall be returned to General Motors LLC, with the exception of any notes, lists, memoranda, indexes or compilations prepared by counsel which constitute work-product. SO ORDERED AND ADJUDGED on this the ioft_ dayof~u+M~,,,,_/_~_ _, 2016. UNITED STATES DIST 2 CT JUDGE APPROVED BY: Isl James W. Harris James W. Harris Law Office of James W. Harris P. 0. Box 185 Blytheville, AR 72316-0185 Attorney.for Plaintiff Isl Paul V. Cassisa Jr. Paul V. Cassisa, Jr. BUTLER SNOW LLP P.O. Box 1138 Oxford, MS 38655 Attorney.for General Motors LLC 31974139vl 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?