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Aggreko, LLC v. Barreto

United States District Court, D. North Dakota, Western Division

April 14, 2017

AGGREKO, LLC, Plaintiff,
v.
GUILLERMO BARRETO and ELITE POWER, LLC, Defendants.

          STIPULATED PROTECTIVE ORDER

          CHARLES S. MILLER, JR., MAGISTRATE JUDGE.

         The parties, by and through their respective counsel, stipulate to the entry of this Protective Order concerning confidential information, as follows:

         1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure and designated as "CONFIDENTIAL" pursuant to the terms of this Protective Order.

         2. As used in this Protective Order, "document" is defined as provided in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.

         3. "CONFIDENTIAL" information covered under the terms of this protective order shall include documents, materials and/or information produced either by Aggreko, LLC ("Plaintiff), or by Guillermo Barreto and/or Elite Power, LLC ("Defendants"), when designated as "CONFIDENTIAL" as provided herein, (a) concerning current or former employees of Aggreko or Elite Power (including Guillermo Barreto), including personnel or personnel-related documents or internal memoranda; (b) concerning business or financial documents, information, research, development or commercial information, which any party contends is proprietary, confidential or a trade secret; (c) concerning personal information relating to any employee of Aggreko or Elite Power and (d) obtained through releases concerning personal identification, financial and/or tax records, when designated as "CONFIDENTIAL." As a condition of designating documents "CONFIDENTIAL, " the documents must be reviewed by a lawyer of the designating party who will certify that the designation as "CONFIDENTIAL" is based on a good faith belief that the information is confidential or otherwise entitled to protection under Fed.R.Civ.P. 26(c)(7).

         4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

         5. CONFIDENTIAL information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:

(a) attorneys working on this case;
(b) persons regularly employed or associated with the attorneys working on the case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties and designated representatives for Aggreko and Elite Power;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
(e) the Court and its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
(g) deponents, witnesses, or potential witnesses; and (h) other persons by written ...

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