Free Motion for Protective Order - District Court of Connecticut - Connecticut

·l J Case 3:03-cv—0O378—DJS Document 25 Filed 1 1/21 /2003 Page 1 of 4 `
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UNITED STATES DISTRICT COURT _ __ ‘· *i
DISTRICT OF CONNECTICUT ry \ EQ Qi gg
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Plaintiff, ) CIVIL ACTION l
) 3:03-CV-378 (DIS) I
v. )
)
GEORGIA-PACIFIC, )
)
Defendant. ) I E
) November 14, 2003 ‘
CONSENT PROTECTIVE ORDER AS TO THE
PRODUCTION OF CONFIDENTIAL DOCUMENTS
The parties having consented, they hereby respectfully request that the following
Protective Order, pursuant to Fed. R. Civ. P. 26(c), be entered upon approval of the
Court. I
As used herein, the word(s) "document" or "documents" shall be taken to mean i
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(a) all papers, documents, recordings of any kind and printed materials produced, i
furnished by, or obtained from Georgia-Pacific Corporation ("Georgia-Pacific" or
"Defendant") through discovery in this action on or after the date this action was filed;
(b) all copies, extracts, and complete or partial summaries prepared from such papers or
documents; (c) portions of deposition transcripts and exhibits thereto which quote or
reference directly the text of any such papers, documents, copies, extracts or summaries;
(d) portions of briefs, memoranda, or any other writings tiled with the Court and exhibits
thereto, which quote or reference the contents of any such papers, documents, copies,
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extracts, or summaries. i

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IT IS HEREBY ORDERED that:
1. All documents, together with information contained therein or obtained _
therefrom, produced by Plaintiff and/or Defendant shall be treated as confidential by Q
all parties to this litigation and shall be used exclusively in connection with this I
litigation. {
2. No documents shall be exhibited, or shown to any person except: N
(a) named parties — including Donna Owen — and attorneys of record representing
named parties in this case; (b) persons employed by such attorneys in the preparation
and trial of this case; (c) officers, agents, managers, and employees of Georgia-Pacific
assisting counsel in preparation of the defense of this action; (d) potential deposition
or trial witnesses who already know or have a need to know the content of the I
document; (e) officials of the Court; and (i) any other individuals with prior written
consent by both parties or by order of the Court. Any person to whom disclosure is
made shall be furnished with a copy of this Protective Order and shall be subject
thereto.
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3. Any inadvertently produced document about which a claim of work E
product or attorney/client privilege is asserted will be returned to its rightful owner,
without any copies being made or retained, and will be regarded as not having been
produced.
4. Any document tiled with the Court shall be clearly marked
"contidential” and shall be kept by the Clerk under seal and made available only to
the Court and persons authorized by the terms of this Protective Order to have access
thereto. The person filing any such designated documents shall inform the Clerk that I
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I J l _ D Case 3:03-cv—0O378—DJS Document 25 Filed 1 1/21 /2003 Page 3 of 4 i
all or designated portions thereof are subject to this Protective Order and are to be i
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kept under seal, except that upon the default of the filing party to so inform the Clerk, `
any party may do so.
5. Should either party object to the confidentiality of any document
pursuant to this Order, the objecting party may apply to the Court by motion for a l
ruling that the document shall not be so treated, after giving ten (10) days written i
notice of such objection to the other party. Until the Court rules upon such a motion,
the subject document shall be afforded the confidential treatment provided for in this l
Order.
6. Plaintiff will be entitled to full access to documents produced to
Plaintiff and subject to this Order and all copies thereof for her review; except that
with respect to such documents, at all times Plaintiff’s counsel will retain sole
possession of all documents, including documents containing information derived
therefrom and all copies of such documents.
7. Prior to making disclosures to experts pursuant to paragraph 2 above,
counsel shall inform experts that documents (and information therein) shall be used
for the purpose of the prosecution or defense of this action only, and counsel for the
parties shall obtain from such persons a written statement that they have read this
Order, agree to be bound by its provisions, and shall comply with its terms and
conditions. Counsel agree to retain in their possession all of the written statements
signed by those persons, thereby keeping record of persons to which disclosures are
made. All documents, including copies of such documents, shall be returned to
counsel by persons given access to them as soon as practicable. i
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8. At the conclusion of this litigation, all documents as defined above,
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including all copies thereof, shall be returned to the party who provided the document
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within twenty (20) days. 1
9. This Order is without prejudice to the right of any party to make R
modification or amendment of this Order by further order of the Court upon motion
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and notice.
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SO ORDERED this day of November, 2003. I
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District Court Judge Presiding y
AGREED AND CONSENTED TO:
O EN GEORGIA—PAClFIC `
By: - I : » g l
Stephe . Horner Ran all . vram
Law Office of Stephen P. Horner Richard D. Haygood
2183 Boston Post Road Kilpatrick Stockton LLP
Darien, Connecticut 06820 3737 Glenwood Avenue, Suite 400
Raleigh, North Carolina 27612
Gregory B. Nokes
Cummings & Lockwood
CityPlace 1
185 Asylum Street
Hartford, Connecticut 06103-3495 l
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