Doe et al v. Marriott International, Inc. et al

Filing 33

CONSENT PROTECTIVE ORDER. Signed by US Magistrate Judge Susan C. Rodriguez on 1/7/25. (mga)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
3:24-cv-344-SCR
JOHN DOE and JANE DOE,
Plaintiffs,
v.
MARRIOTT INTERNATIONAL, INC., et al.
Defendants.

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CONSENT PROTECTIVE ORDER
The parties possess trade secrets and/or other confidential, propriety, and commercially
sensitive information and personal identifying information or personal health information that each
may need to disclose to the other during discovery in the above-captioned matter (the “Action”).
The parties have, through counsel, stipulated to the entry of this Protective Order (“Order”),
pursuant to Rule 26 of the Federal Rules of Civil Procedure to facilitate discovery in the Action
while protecting such confidential information from improper disclosure and use.
The parties have established good cause for the entry of this Order.
THEREFORE, IT IS ORDERED AS FOLLOWS:
1.

DEFINITIONS
1.1

“Material” means documents or other information, including electronically stored

information, within the meaning of Fed. R. Civ. P. 34 produced in this Action, whether pursuant to
the Federal Rules of Civil Procedure, by subpoena, or by agreement, other than documents
that are publicly available; interrogatory or other discovery responses; responses to request for
admissions and deposition testimony taken in this action, exhibits thereto and/or any videos or
transcripts thereof, whether in written or computer format, and all contents of the foregoing.

1.2

“Confidential” or “Confidential Material” means any document, material, or

information the Producing Party believes in good faith constitutes or discloses information that
qualifies for protection pursuant to Fed. R. Civ. P. 26(c), specifically information that identifies or
could reasonably lead to the identification of parties who are proceeding in this action
anonymously, is trade secret as defined by the Uniform Trade Secrets Acts, and/or research,
development, or other proprietary and/or commercially sensitive information and any other
confidential or proprietary information not generally available to the public, disclosure of which
may result in harm to the party’s competitive position.
Confidential Material may also include documents and information that contain personal
medical information or other personal information pertaining to patients; and Protected Health
Information (PHI) and individually identifiable health information that is protected from
unauthorized disclosure by the HIPAA, codified in 45 C.F.R. §§ 160, 164.“Producing Party”
means any party or non-party producing Material or Confidential Material in this Action, whether
pursuant to the Federal Rules of Civil Procedure, by subpoena, or by agreement.
1.3

“Receiving Party” means any party that receives Material or Confidential Material

from a Producing Party in this Action, whether pursuant to the Federal Rules of Civil Procedure, by
subpoena, or by agreement.
1.4

“Designating Party” means any party that designates as “Confidential” or

“Confidential Material” any Material produced by that party, another party, or a non-party, or any
non-party that designates information or material that it produces in this Action as confidential,
whether pursuant to the Federal Rules of Civil Procedure, by subpoena, or by agreement.
1.5

“Attorneys of Record” means any attorney of record for any of the parties to this

Action, members of the firm of the attorneys of record for the parties, and any in-house attorneys

who are employed by the parties.
2. DESIGNATING MATERIAL AS CONFIDENTIAL
2.1

Manner and Timing of Designations. Except as otherwise provided in this

Protective Order, or as otherwise stipulated or ordered, Confidential Material must be clearly
designated “CONFIDENTIAL” when the Material is disclosed or produced. If a Producing Party
discovers that Confidential Material inadvertently was not designated as “CONFIDENTIAL”
when it was produced, the Producing Party, within a reasonable time, may notify Counsel for the
opposing party and may provide a substitute production bearing the designation of
“CONFIDENTIAL.”
a.

For information in documentary form (apart from transcripts of depositions), the

Producing Party must affix the legend “CONFIDENTIAL- SUBJECT TO PROTECTIVE
ORDER” at the bottom of each page (within printable margins of the document and not
covering any text) that contains Confidential Material.
A party or non-party that makes original Materials available for inspection need not
designate them for protection until after the Receiving Party has indicated which Material
it would like copied and produced. During the inspection and before the designation, all of
the Material made available for inspection shall be treated as Confidential Material. After
the Receiving Party has identified the documents he/she/it wants copied and produced, the
Producing Party may designate documents as Confidential Material in accordance with the
terms of this Order. The Producing Party must affix the legend “CONFIDENTIAL SUBJECT TO PROTECTIVE ORDER” at the bottom of each page that contains
Confidential Material.

b.

For testimony given in deposition proceedings: All witnesses to whom Confidential

Materials are disclosed must either:
i.

agree in writing to the non-disclosure agreement attached hereto as Exhibit
A, and are hereby ordered (1) to maintain Confidential Materials in
confidence and (2) not to disclose Confidential Materials to anyone other
than in accordance with the terms of this Protective Order;
OR

ii. Any deponent who agrees on the record to adhere to the following directive:
“There is a confidentiality order in effect in this litigation. We have a copy
you can review, if you request. But the parties have agreed to the following
explanation, instead of taking the time for you to review the order. Under
the confidentiality order, you are required to hold in confidence any
confidential information you are shown or otherwise provided during the
course of this deposition. You cannot disclose confidential contents to
anyone. They are only being used for the purposes of this deposition and
cannot be used or disclosed to anyone else, which means you cannot talk
about or otherwise share or discuss their contents. If you violate these
directives under the confidentiality order, you may be subject to sanctions
by the Court and by any other remedies the parties to this litigation may seek.
Do you understand that you are required to follow these requirements?”
The deponent may not change this agreement with an Errata.

c.

Confidential Materials disclosed at a deposition may be designated by a party as

Confidential Materials by indicating on the record at the deposition that the specific part of

the testimony and/or any exhibits marked for identification is confidential, and is subject to
the provisions of the Protective Order. Counsel for any party may exclude from the room
during any portion of a deposition any person not entitled under this Protective Order to
receive Confidential Materials while such materials are being disclosed and/or discussed.
Alternatively, a party may designate Confidential Materials disclosed at such depositions
as confidential by notifying all persons appearing on the record at the deposition in writing,
within thirty (30) days of receipt of the witness’s transcript, of the specific pages and lines
of the transcript which contain Confidential Materials. Each party shall attach a copy of such
written statement to the face of the transcript and each copy thereof in his or her possession,
custody or control. During such thirty (30) day period, the deposition transcript and all
exhibits thereto shall be treated as Confidential Material. To the extent that filings are
required with the Court within this thirty (30) day period, the parties will meet and confer
to attempt to determine whether any portion of the deposition should be designated as
confidential.
d.

For Confidential information produced in some form other than documentary and

for any other tangible items, the Producing Party must affix in a prominent place on the
exterior of the container or containers in which the information or item is stored the legend
“CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.”
2.2

By making Confidential Materials available during the course of this Action, the

Producing Party does not waive any trade secret or other confidential protection that might
otherwise be afforded over those Materials. Furthermore, by designating any Confidential
Materials as “CONFIDENTIAL,” the parties do not acknowledge or agree that any such
Confidential Materials are relevant, admissible, or discoverable in this Action. This Protective

Order shall not constitute a waiver of any right to seek discovery of, or alternatively to resist
discovery of, any Material in this Action.
2.3

Inadvertent Failures to Designate as Confidential. Inadvertent failure to designate

Materials at the time of production as Confidential does not, standing alone, waive the Producing
Party’s right to thereafter designate such Materials as Confidential.
2.4

Inadvertent failure to designate Materials as Confidential at the time of production

may be remedied by supplemental written notice and by production of replacement Materials with
the “CONFIDENTIAL” designation. Upon such notice and replacement production, the Receiving
Party shall use his/her/its best efforts to destroy the previously-produced Materials and shall make
reasonable efforts to ensure that the Material is treated as Confidential. The inadvertent disclosure
by the Producing Party of Confidential Materials, regardless of whether such Materials were so
designated at the time of disclosure, shall not be deemed a waiver, in whole or in part, of a party’s
claim of confidentiality, either as to the specific Materials disclosed or as to any other Confidential
Materials relating thereto or on the same or related subject matter.
If the Receiving Party in good faith wishes to challenge the Confidentiality designation
under this section, it may do so after meeting and conferring with the Producing Party and after
emailing the Court (with the Producing Party copied on the email) to inquire as to the manner in
which the Court prefers to address the dispute; no motions may be filed without leave of Court.
The Producing Party bears the ultimate burden of establishing that the Material is entitled to
protection.
2.5

The terms of this Order shall in no way affect the right of the Producing Party to

withhold Material(s) on the grounds of immunity from discovery, including the attorney client
privilege, joint defense privilege, work product doctrine, or any other applicable privilege, all of

which must be recognized under the law, or to exclude from production Material(s) on the grounds
that such Material(s) are beyond the scope of discovery defined in Fed. R. Civ. P. 26(b)(1).
Inadvertent production or other disclosure of Material(s) subject to work-product
immunity, the attorney-client privilege, joint defense privilege, or other legal privilege or
protection that protects information from discovery shall not constitute a waiver of the immunity,
privilege, or other protection, provided that the Producing Party promptly notifies the Receiving
Party after the Producing Party becomes aware of such inadvertent production. Upon notification,
the Receiving Party shall immediately return, sequester or destroy the inadvertently-produced
Material(s) and all copies as well as notes, summaries, and/or work product reflecting the contents
of such materials. If only a portion of the Material(s) is privileged, the Producing Party shall
provide a new version of the Material(s) in which the privileged information has been redacted.
No further use or disclosure shall be made of the inadvertently-produced Material(s), and the
Receiving Party shall take all reasonable and appropriate steps to retrieve the Material(s), and all
copies, from any person who has received Material(s) through the Receiving Party. The parties
shall have the benefit of all limitations on waiver afforded by the Federal Rules of Civil Procedure
and Federal Rules of Evidence 501 and 502.
If a Producing Party claws back Material(s) under this paragraph that is/are identified for
use at or attempted to be used at a deposition, and if the Producing Party refuses to allow the
deponent to be questioned regarding the clawed back Material(s), the parties acknowledge that
they shall attempt to bring the issue to the attention of the Court during the deposition. If the Court
is unable to address the issue at the time raised, the Producing Party may make an oral motion for
protective order pursuant to Fed. R. Civ. P 30(d)(3) and instruct the witness not to answer any
questions about the subject Material(s), but the parties may meet and confer after the deposition to

address those issues and, if necessary and appropriate, jointly contact the Court with regard to the
issue or agree to table the issue until such time as they can further meet and confer. In the event
the parties later agree, or the Court later rules, that the subject Materials are not privileged and/or
that the deponent may be questioned about the subject Materials, the Producing Party shall be
responsible for all logistics necessary to reconvene the deposition at a mutually convenient time,
date, and place to permit the witness to be questioned about the subject Materials, and the
Producing Party shall pay court reporter costs and any third-party witness costs for the reconvened
deposition as well as any costs, including legal fees, which the Court may award.
2.6

Corrected Designation. If it comes to a Producing Party’s attention that Material

he/she/it previously designated as Confidential Material is not confidential under the terms of this
Order, the Producing Party shall notify Counsel for the opposing party that he/she/it is withdrawing
the confidentiality designation. In such case, the Producing Party shall re-produce the Material
without any Confidentiality markings.
3.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
3.1

Timing of Challenges. Any party may challenge a designation of confidentiality

within a reasonable time after the party first believes that certain Material designated as
Confidential should not be so designated. A party does not waive its right to challenge a
confidentiality designation by electing not to mount a challenge immediately after the original
designation is disclosed, but shall do so within a reasonable time.
3.2

Procedure for Parties Challenging Confidentiality Designations. A party may

challenge the designation of Confidential Materials as follows:
In the event that any party disagrees with the designation by the Producing Party of
Confidential Materials as being Confidential, the parties shall first try to dispose of such

dispute in good faith on an informal basis by conferring directly with counsel for the
Producing Party. The party challenging the confidentiality designation shall provide to the
Producing Party written notice of that disagreement, stating the reason(s) for the challenge.
During the 10-day period following the receipt of the written notice to the Producing Party,
the party challenging the confidentiality and the Producing Party shall try to resolve such
challenge in good faith on an informal basis (the “Meet and Confer Period”).
If the dispute cannot be resolved, the party challenging the designation may email the Court
(with the opposing party copied on the email) and seek leave of Court to present the dispute,
even within the meet and confer period if such guidance is needed from the Court. Any
objections to such a designation, when made, shall be in writing and shall specify the nature
of any objection. Any Materials that are being challenged shall remain as Confidential
Materials under the terms of this Protective Order until the Court makes a determination
otherwise. The Producing Party bears the ultimate burden of establishing that the Material
is entitled to protection.
4.

PROCEDURE FOR FILING DOCUMENTS UNDER SEAL
4.1

Without written permission from the Producing Party or a court order secured after

appropriate notice to all interested persons, a party may not file in the public record in this Action
any Confidential Materials. In the event disclosure of sealed materials is sought, no portion of the
materials thus sealed shall be released except upon notice to the Producing Party made by the party
seeking disclosure, proof of which shall be made to the Court, and after a full opportunity for
hearing upon the matter.
4.2

Confidential Material shall not be filed with the Court except when required in

connection with matters pending before the Court. Any documents (including briefs), tangible

things, or information designated as Confidential Material that are submitted to the Court in support
of or in opposition to a motion or introduced at a hearing may retain their protected confidential
status only by compliance with the Court’s Procedures for Electronic Filing Under Seal in Civil
Cases pursuant to LCvR 6.1. Said Confidential Material shall be kept under seal until further order
of the Court; however, Confidential Material and other papers filed under seal shall be available to
the Court, to counsel of record, and to all other persons entitled to receive the confidential information
contained therein under the terms of this Protective Order.
4.3

The party seeking to file the Confidential Materials shall first consult with the

counsel for the party who designated the Material as confidential to determine if some measure
less restrictive than filing the Material under seal may serve to provide adequate protection. A mere
reference or discussion of confidential information does not warrant sealing of the entire document
and all attachments to be filed. The parties should meet and confer in good faith to address the
sealing (or filing in a redacted format) of those portions of the Materials that contain or refer to
confidential information.
5.

ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
5.1

A Receiving Party may use Confidential Material in connection with this Action

only for prosecuting, defending, or attempting to settle this Action. Confidential Material may be
disclosed only to the categories of persons and under the conditions as are described herein.
Disclosure of Confidential Materials other than in accordance with the terms of this Protective
Order may subject the disclosing party to such sanctions and remedies as the Court may deem
appropriate.
Confidential Material must be stored and maintained by a Receiving Party at a location and
in a secure manner that ensures that access is limited to the persons authorized under this Protective

Order.
5.2

Disclosure of Confidential Material. Unless otherwise ordered by the Court or

permitted in writing by the Producing Party, Confidential Material may be disclosed only to the
following persons and only to the extent such persons have a legitimate need to know the particular
Confidential Material disclosed to them:
a.

Attorneys of Record;

b.

Employees of the Attorneys of Record working under the direct supervision of such

Attorneys of Record;
c.

Parties to this Action and their in-house attorneys, officers, directors, and

employees;
d.

Insurance adjusters and/or third-party administrators responsible for handling this

matter on behalf of the Parties to this action;
e.

Experts or consultants, provided that prior to any disclosure the Attorney of Record

who retains the outside expert or consultant obtains a signed “Acknowledgment and
Agreement to Be Bound by Stipulated Protective Order” (Exhibit A);
f.

The Court or persons employed by the Court in connection with the handling of this

Action;
g.

Litigation support services, including outside copying services, court reporters,

stenographers, videographers, or companies engaged in the business of supporting
computerized or electronic litigation discovery or trial preparation, retained by a party for
the purpose of assisting that party in these proceedings, for whom a company representative
has signed the “Acknowledgment and Agreement to Be Bound by Protective Order”
(Exhibit A);

h.

Any actual or potential witness in this Action who has signed the

“Acknowledgment and Agreement to Be Bound by Stipulated Protective Order” (Exhibit
A), or otherwise agrees in writing that he/she will not disclose the Confidential Material to
anyone, provided that Attorney of Record believes, in good faith, that such disclosure is
reasonably necessary for the prosecution or defense of these proceedings;
i.

Any deponent in this Action who has signed the “Acknowledgement and

Agreement to Be Bound by Stipulated Protective Order” (Exhibit A) or has agreed to
maintain the confidentiality of such documents as set forth in section 2.1.b.ii. above, except
that an employee of a Producing Party need not sign Exhibit A with regard to the Producing
Party’s Confidential Material.
j.

The author(s) of the document, any persons who received the document other than as

part of a lawsuit, claim, or litigation, or the original source(s) of the document;
k.

Counsel for issuers of insurance policies under which any issuer may be liable to

satisfy part or all of a judgment that may be entered in these proceedings or to indemnify
or reimburse payments or costs associated with these proceedings, if any, and who has
signed the “Acknowledgment and Agreement to Be Bound by Stipulated Protective Order”
(Exhibit A);
l.

Any mediator or arbitrator appointed by the Court or selected by mutual agreement

of the parties and the mediator or arbitrator’s secretarial and clerical personnel, provided
that a company representative for the mediator or arbitrator has signed the
“Acknowledgment and Agreement to Be Bound by Stipulated Protective Order” (Exhibit
A);
m.

Any other person who signs an undertaking in the form of Exhibit A, agreeing in

writing to be bound by the terms and conditions of this Protective Order, consenting to
the jurisdiction of the Court for the purposes of the enforcement of this Protective Order,
and agreeing not to disclose or use any Confidential Material in a manner or for purposes
other than those permitted hereunder.
n.

Any other person as to whom the Producing Party has consented to disclosure in

advance and in writing. Consent will not be unreasonably withheld upon good faith request.
5.3

Before disclosing any Confidential Materials to any person specified in paragraphs

5.2(e), (g), (h), (i), (k), or (l), above, disclosing counsel shall advise said persons of this Protective
Order and said person must agree in writing to the non-disclosure agreement attached hereto as
Exhibit A, which states that such persons agree (1) to be bound by the terms hereof, (2) to maintain
the Confidential Materials in confidence, and (3) not to disclose the Confidential Materials to anyone
other than in accordance with the terms of this Protective Order. Each party shall maintain a file
containing such certifications.
5.4

Nothing in this Protective Order restricts a Producing Party’s ability to use or

disclose its own Confidential Materials.
6.

CONFIDENTIAL
MATERIAL
SUBPOENAED
PRODUCED IN OTHER LITIGATION

OR

ORDERED

If a Receiving Party is served with a subpoena or an order issued in other litigation that
would compel disclosure of Confidential Material, the Receiving Party must so notify the Producing
Party in writing by e-mail within ten (10) business days after receiving the subpoena or order. Such
notification must include a copy of the subpoena or court order.
The Receiving Party also must promptly notify in writing the party that caused the subpoena
or order to issue that some or all the material covered by the subpoena or order is the subject of this

Protective Order. In addition, the Receiving Party must deliver a copy of this Protective Order
promptly to the party in the other action that caused the subpoena or order to issue.
If the Producing Party timely seeks a protective order from the court where the subpoena
or order issued and provides timely notice of such filing to the Party served with the subpoena or
court order, then the Party so served shall not produce any Confidential Material before a
determination by that court, unless the party has obtained the Producing Party’s permission. The
Producing Party shall bear the burden and expense of seeking protection in that court of its
Confidential Material.
7.

UNAUTHORIZED DISCLOSURE OF CONFIDENTIAL MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Confidential

Material to any person or in any circumstance not authorized under this Protective Order, the
Receiving Party must promptly (a) notify in writing the Producing Party of the unauthorized
disclosures, (b) use its best efforts to retrieve all copies of the Confidential Material, (c) inform the
person or persons to whom unauthorized disclosures were made of all the terms of this Order, and
(d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound
by Stipulated Protective Order” that is attached hereto as Exhibit A.
8.

USE OF CONFIDENTIAL MATERIAL IN COURT HEARINGS
Confidential Material may be introduced by a party at a court hearing in this Action provided

that any disputes that may arise with regard to its use will be resolved by the Court at the time and
prior to the introduction of the Confidential Material. The party seeking to introduce Confidential
Material at the Court hearing shall notify the Producing Party no later than the day before the
hearing of any such intent. Nothing in this Protective Order shall determine the admissibility into
evidence of Confidential Materials or abridge the rights of any person to seek judicial review or to

pursue other appropriate judicial action with respect to any ruling made by the Court.
The terms of this Protective Order shall not be construed as any limitation upon the right
of any party to offer into evidence any documents, response, or information designated as
confidential.
9.

DURATION
Even after final disposition of this Action, the confidentiality obligations imposed by this

Order shall remain in effect until a Producing Party agrees otherwise in writing or a court order
otherwise directs.
At the conclusion of this Action, or any action transferred by the Court to a different venue,
including any appeals from any judgment or order entered by the Court or any transfers of a
particular case by this Court, at the request of the Producing Party, the Receiving Party shall, with
regard to any Materials not unsealed during the Action, retrieve all Confidential Materials from
testifying experts, consulting experts, and any other person or entity to whom the Receiving Party
has disclosed Confidential Materials, and, at its option, within thirty (30) days either: (1) destroy all
Confidential Materials received by such party and shall certify in writing that such destruction has
occurred; or (2) return all received Confidential Materials to the Producing Party and certify in
writing that all such discovery materials have been returned. If the Producing Party is not notified
of which option the Receiving Party has chosen, it will be presumed that option (1) was chosen.
Upon written request of the Producing Party, the Receiving Party shall confirm that one of the
foregoing options has been implemented. However, notwithstanding any other provision of this
paragraph, all Confidential Materials shall remain subject to this Protective Order.
10.

MISCELLANEOUS
10.1

This Protective Order shall be binding upon the parties hereto, counsel for the

parties, and upon the parties’ and their counsels’ successors, executors, personal representatives,
administrators, heirs, legal representatives, assigns, subsidiaries, divisions, employees, agents,
independent contractors, and other persons or organizations over which they have control. The
parties, their counsel and employees of such counsel, and their expert witnesses, consultants and
representatives retained in connection with this action each expressly stipulates to the personal
jurisdiction of this Court for purposes of any proceeding brought by a party to this action to enforce
this Protective Order.
10.2

This Court retains jurisdiction over the parties, counsel for the parties, and all

persons, firms, corporations or organizations to whom this Protective Order applies for purposes
of enforcement of this Protective Order following the conclusion of this action.
10.3

Right to Assert Other Objections. No party waives any right to object

on any ground to use in evidence of any of the material covered by this Protective Order.
10.4

Disposition of Confidential Materials. The ultimate disposition of protected materials

is subject to a final order of the Court on the completion of the litigation. Any motion, memorandum,
document or paper filed with the court is presumptively a public document and any decision
regarding whether to allow any filing to be made under seal is subject to Local Rule 6.1 and
applicable law.
SO ORDERED.
Signed: January 7, 2025

WE ASK FOR THIS:

/s/ Jeffrey A. Breit______________________
Jeffrey A. Breit, Esq. (NCSB No. 17820)
Lee Adair Floyd, Esq., admitted Pro Hac Vice
Sarah G. Sauble, Esq., admitted Pro Hac Vice
Breit Biniazan, PC
2100 East Cary Street, Ste. 310
Richmond, VA 23223
Telephone: [phone]
Facsimile: 757-670-3939
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiffs

/s/ Todd A. King______________________
Todd A. King (NCSB No. 28621)
Cranfill Sumner LLP
P.O. Box 30787
Charlotte, North Carolina 28230
Telephone: [phone]
Facsimile: 704-332-9994
[e-mail]
Counsel for Defendant Parking Management Company

/s/Charles A. Kinney_______________________
Charles A. Kinney (NCSB No. 41367)
Thomas G. Tidwell, admitted Pro Hac Vice
Luciana Aquino, admitted Pro Hac Vice
Cozen O’Connor
301 S. College Street, Suite 2100
Charlotte, North Carolina 28202
Telephone: [phone]
Facsimile: 704-334-3351
[e-mail]
[e-mail]
Counsel for Defendants Marriott International, Inc., CWI 2 Charlotte Hotel, LP, and Charlotte 2
Hotel Operator, LLC.

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
Charlotte Division

JOHN DOE and JANE DOE,
Plaintiff,
v.

CIVIL NO. 3:24-cv-344

MARRIOTT INTERNATIONAL, INC., et al.
Defendants.

EXHIBIT A TO THE PROTECTIVE ORDER
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND BY THE
PROTECTIVE ORDER
I acknowledge that Confidential Materials are being provided to me pursuant to the terms
and conditions of the Protective Order entered in the above styled action on

, 2025.

I further certify that I have been provided a copy of and have read and understand the
Protective Order. I understand and agree that I am personally bound by and subject to all of the
terms and provisions of the Protective Order. I understand that the Protective Order prohibits me
from either using or disclosing Confidential Materials for any purpose other than as set forth in and
pursuant to the Protective Order entered by the Court.
I understand that failure to abide by the terms of the Protective Order may subject me to
sanctions, including contempt of court, for such failure. I hereby agree to subject myself to the
jurisdiction of the Court for purposes of enforcement of the terms and conditions of the Protective
Order.

Signed this

day of

, 20

.

Signature

Printed Name
(ADDRESS & NUMBER)