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Anthony v. Harmon

February 1, 2010

CARMELO ANTHONY, ET AL., PLAINTIFFS,
v.
LARRY HARMON, ET AL., DEFENDANTS.



AMENDED STIPULATED PROTECTIVE ORDER

Subject to the approval of this Court, plaintiffs Carmelo Anthony, Melo Enterprises, Inc. and Chosen One Properties, LLC and defendants Larry W. Harmon, Frank Castillo, Larry Harmon & Associates, P.A., Harmon-Castillo, LLP and Vitalis Partners, LLC, by and through their counsel of record, hereby stipulate and agree to the following protective order:

1. Purposes and Limitations

In connection with discovery proceedings, this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than in the prosecution, defense or settlement of this action would be warranted. The parties acknowledge that this Order is entered solely for the purpose of facilitating the exchange of documents and information between the parties to this action without involving this Court unnecessarily in the process. Nothing in this Order nor the production of any information or document under the terms and conditions of this Order nor any proceedings pursuant to this Order shall be deemed to have the effect of an admission or waiver by any party or of altering the confidentiality or nonconfidentiality of any such document or information or altering any existing obligation of any party or the absence thereof.

2. Designation of Confidential Information

2.1 The parties may designate any document, thing, material, testimony or other information derived therefrom as "confidential" under the terms of this Stipulated Protective Order (hereinafter "Order"). Confidential information means any information or documents concerning which the designating party has a good faith basis to believe that comprise of or contain information that qualify for protection under the standards developed under rule 26(c) of the Federal Rules of Civil Procedure and under any other applicable law from disclosure or provides for limited disclosure.

2.2 By designating a document, thing, material, testimony or other information derived therefrom as "confidential" under the terms of this Order, the party making the designation is certifying to the Court that there is a good faith basis both in law and in fact for the designation within the meaning of Federal Rules of Civil Procedure rule 26(g).

2.3 Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multi-page document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party.

2.4 Material designated as confidential under this Order, the information contained therein, and any summaries, copies, abstracts or other documents derived in whole or in part from material designated as confidential (hereinafter "confidential material") shall be used only for the purpose of the prosecution, defense or settlement of this action, and for no other purpose.

2.5 Confidential material produced pursuant to this Order may be disclosed or made available only to the Court, to counsel for a party (including the paralegal, clerical and secretarial staff employed by such counsel), and to the "qualified persons" designated below:

(a) A party, or an officer, director or employee of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action;

(b) Experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, defense or settlement of this action;

(c) Court reporter(s) employed in this action; (d) A witness at any deposition or other proceeding in this action; and (e) Any other person as to whom the parties in writing agree. 2.6 Prior to receiving any confidential material, each "qualified person" shall be provided with a copy of this order and shall execute a non-disclosure in the form of Attachment A, a copy of which shall be provided to counsel for each other party and for the parties.

2.7 Depositions shall be taken only in the presence of ...


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