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)

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.