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Alcazar v. Target Corp.

United States District Court, D. North Dakota

September 19, 2017

Candice Alcazar, Plaintiff,
v.
Target Corporation, Defendant.

          Jim Nostdahl (#3925) ATTORNEYS FOR CANDICE ALCAZAR.

          Brenda L. Blazer (#04155) Vogel Law Firm ATTORNEYS FOR TARGET CORPORATION.

          STIPULATED PROTECTIVE ORDER

          CHARLES S. MILLER, JR., MAGISTRATE JUDGE UNITED STATES DISTRICT COURT

         It is hereby stipulated and agreed among the parties to this action, through their undersigned counsel:

         1. This Stipulated Protective Order governs the handling of information defined in Paragraph 2 as “Confidential Discovery Material” that is produced in this litigation by defendant Target Corporation (“Target”).

         2. For purposes of this Stipulated Protective Order, “Confidential Discovery Material” shall include all paper documents, testimony and electronic files considered by Target to constitute or contain trade secrets or other confidential information including but not limited to video recordings, and any other similar materials produced by Target in this action and marked “CONFIDENTIAL.” How materials are marked will depend upon whether they are hard copy documents or electronic files. Such designations may also be made to testimony in the course of depositions or during any hearings or trial of this proceeding. Documents or other materials inadvertently produced with a designation of “CONFIDENTIAL” may automatically be designated as “CONFIDENTIAL” upon written notice to all Parties within thirty (30) days following the production of such documents or materials, and such documents or materials will be treated as Confidential Discovery Material subject to this Stipulated Protective Order upon such notice.

         3. Except as otherwise provided in this Stipulated Protective Order, all Confidential Discovery Material shall be deemed to be confidential and may be used by the persons receiving it only for the purpose of preparing for and conducting pretrial and trial proceedings and appeals, if any, in this action and for no other purpose.

         4. Except as otherwise provided in this Stipulated Protective Order and except as may be required by law, Confidential Discovery Material may be disclosed only to the following persons and only after full compliance with paragraph 5, if applicable:

(a) attorneys (and their staff) appearing as counsel of record for one of the parties hereto;
(b) consultants and experts retained by a party to this action, to the extent deemed necessary by counsel of record for the prosecution or defense of this action;
(c) court reporters in connection with the recording of sworn testimony;
(d) the Court, if filed or introduced pursuant to paragraph 8;
(e) officers and managers of the parties who are assisting counsel of record in preparation of ...

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