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Browne v. Cypress Energy Mangement, LLC

United States District Court, D. North Dakota

April 18, 2017

Victor N. Browne Jr., Jimmie Breckenridge, Shane Ellinger, Gary Klein, Blake Schaat Roger Tofslie and Tracy Tofslie, Plaintiffs,
v.
Cypress Energy Management, LLC, and Cypress Energy Management - Bakken Operations, LLC, Defendants.

          Leo F.J. Wilking Law Firm, PLLC Attorney for Plaintiffs

          Joseph M. Sokolowski (MN Bar No. 0178366)* Eli K. Best (MN Bar No. 0395212)* FREDRIKSON & BYRON, P.A. Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER

          Charles S. Miller, Jr., Magistrate Judge:

         I. SCOPE AND IMPLEMENTATION OF THE PROTECTIVE ORDER

         1. This Stipulated Protective Order (“Protective Order”) will govern the handling and dissemination of documents stamped as CONFIDENTIAL and produced or disclosed in the course of the above-captioned action (“Action”) by Victor N. Browne Jr., Jimmie Breckenridge, Shane Ellinger, Gary Klein, Blake Schaat, Roger Tofslie, Tracey Tofslie, Cypress Energy Management, LLC, or Cypress Energy Management - Bakken Operations, LLC (hereinafter collectively referred to as “Parties”).

         2. All Confidential Information (as the term is hereafter defined) produced formally or informally by the Parties contained in deposition or trial testimony, answers to interrogatories, or responses to requests for documents, including copies, summaries and abstracts of the foregoing, (hereinafter collectively referred to as the “Information”) shall be used solely for the purpose of the above-captioned litigation, and not in connection with any other litigation or judicial proceeding or for any business, commercial, competitive, personal or other purpose whatsoever. However, nothing herein shall prohibit documents or deposition testimony from being turned over to law enforcement agencies.

         II. DESIGNATION OF CONFIDENTIAL INFORMATION

         1. Confidential Information is information which a party reasonably and in good faith would not normally reveal to others unless such others would maintain it in confidence.

         2. Before the production of the Documents and Information containing Confidential Information, the party producing the Documents and Information (“Producing Party”), shall mark each page containing such Confidential Information with a legend substantially in the following form: “CONFIDENTIAL”. If any Confidential Information is disclosed in deposition testimony, the party claiming confidentiality shall notify the other parties of the portion of the testimony for which such treatment is sought within 21 days after receipt of the transcript, and each page of the transcript which contains Confidential Information shall be marked with such a legend and delivered by the party claiming confidentiality to all other parties within a reasonable time period thereafter. Deposition transcripts shall be considered Confidential Information in their entirety until the expiration of the 21-day period.

         3. With regard to non-written materials, such as recordings, magnetic media, photographs and things, containing Confidential Information, the legend shall be affixed to the material, or a container for it, at the time of production.

         4. Excluding law enforcement, Confidential Information shall not be given, shown, made available, or communicated in any way to anyone other than those-persons described in Section III, Paragraph 1, below.

         III. DISCLOSURE OR USE OF CONFIDENTIAL INFORMATION

         1. The party to whom Confidential Information is produced (“Receiving Party”), may disclose, summarize, describe, reveal or otherwise make available the Confidential Information, in whole or in part, only in accordance with the ...


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