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Stevenson v. Whiting Oil And Gas Corp.

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

October 11, 2017

Randall D. Stevenson, a/k/a Randy D. Stevenson, Plaintiff,
v.
Whiting Oil and Gas Corporation, Defendant.

          Peter H. Furuseth, ND ID #04160 FURUSETH OLSON & EVERT, PC Attorneys for Plaintiff

          Paul J. Forster, NDJID #07398 Anthony J. Ford, ND ID #08217 CROWLEY FLECK PLLP Attorneys for Defendant

          STIPULATED CONFIDENTIALITY AGREEMENT

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

         1. All parties to this action, through their counsel, have agreed to abide by terms of this Stipulated Confidentiality Agreement (“Agreement”) and request that its terms be enforced by the Court.

         2. All documents and information produced in discovery in this case shall be used by the opposing party and their attorneys or agents only for the purposes of this litigation and for no other purpose. Nothing in this Agreement limits a party's right to use its own documents or information.

         3. Either the plaintiff or the defendant may designate documents that are produced to the other party as confidential and subject to this Agreement by prominently labeling such document(s) as “Confidential.” The confidential documents and the information contained therein and derived therefrom furnished by the defendant to the plaintiff and by the plaintiff to the defendant shall be used by the plaintiff or defendant only for the purposes of this case and for no other purpose, and under no circumstances shall the plaintiff or the defendant disclose such material to persons other than the following:

a. The parties and their counsel who have appeared of record for the parties in this case, including counsels' staff;
b. Persons especially retained by attorneys for the parties in this litigation to assist in the preparation of this litigation for trial (such as trial consultants or expert witnesses), and only if such person needs such confidential documents;
c. Fact witnesses, provided that the particular witness has a need for such disclosure in order to respond to questions in a deposition or at trial in this case; and
d. Court reporters and court personnel involved in this case.

         4. The confidential documents and the information contained therein or derived therefrom may be disclosed to and discussed with the persons identified in paragraphs 3(a) through 3(d) only on the following terms and conditions:

a. Prior to any such disclosure or discussion, each such person identified in paragraph 3(b) shall sign an agreement to be bound by this Agreement in the form attached as Exhibit A; and
b. The plaintiff and the defendant, as the case may be, shall retain copies of the originals of these agreements and shall deliver copies to the opposing counsel upon the completion of the litigation.
c. In the case of each such person identified in paragraph 3(c), counsel for either party may designate appropriate portions of the record as “confidential, ” ...

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