Mcgaffin et al v. Cementos Argos S.A. et al

Filing 54

Stipulated PROTECTIVE ORDER. Signed by Magistrate Judge G. R. Smith on 4/3/17. (jrb)

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Case4:16-cv-00104-LGW-GRS Document 52-1 Filed 03/28/17 Page lot 18 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION JIM and BECKY McGAFFIN, RACHALE and NATHAN LaVOIE, and DANIEL and STEFANIE NUNN, Plaintiffs, CIVIL ACTION FILE NO.4:16-cv-00104-LGW-GRS V. CEMENTOS ARGOS S.A., ARGOS USA CORF, ARGOS CEMENT,LLC, and ARGOS READY MIX LLC, Defendants. STIPULATED PROTECTIVE ORDER 1. PURPOSES AND LIMITATIONS Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 13.2, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79.7 sets forth the procedures that must be followed and the standards that will be applied when a party seeks pemiission from the Court to file material under seal.

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