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Caluori v. One World Technologies

May 18, 2010

RAYMOND CALUORI, PLAINTIFF,
v.
ONE WORLD TECHNOLOGIES, INC., DEFENDANT.



The opinion of the court was delivered by: Honorable Victor B. Kenton United States Magistrate Judge

STIPULATED PROTECTIVE ORDER AND RELATED COUNTERCLAIM

Honorable Christina A. Snyder

Upon stipulation of counsel for Plaintiff Raymond Caluori ("Caluori") and Defendant One World Technologies, Inc. ("OWT") (collectively referred to as "Parties"), it appearing to the Court that a Protective Order under Rule 26(c) of the Federal Rules of Civil Procedure is necessary and appropriate and will facilitate discovery,

IT IS HEREBY ORDERED THAT:

1. Any Party or non-party producing material or information in this litigation ("Producing Party") may designate such material or information as "Confidential" or "Attorneys' Eyes Only"*fn1 in which case such material or information shall be treated in accordance with the terms of this Protective Order.

2. The term "Confidential" may be applied only to material or information not known to the general public that is produced in this litigation by a Producing Party to any other Party ("Receiving Party"), that the Producing Party in good faith considers to constitute or contain trade secrets or other confidential research and development, know-how, proprietary data, financial results, other non-publicly available information, or commercial information within the meaning of Federal Rule of Civil Procedure 26(c)(1)(G) or that the Producing Party is under an obligation to a third party to maintain as confidential. The Producing Party shall designate material or information as Confidential in the manner described in Paragraphs 3, 4, 11, 13, or 14 of this Protective Order.

3. The term "Attorneys' Eyes Only" may be applied only to such highly confidential materials or information that consist of or contain particularly sensitive technical information relating to research, marketing, manufacture, and production of products; technical, business and research information regarding products; highly sensitive financial information and marketing plans and forecasts, customer lists, pricing data, cost data, customer orders, customer quotations; and any pending or abandoned patent applications, foreign or domestic; as well as such other documents, information or materials that relate to other proprietary information within the meaning of Federal Rule of Civil Procedure 26(c)(1)(G) that the Producing Party reasonably believes is of such nature and character that disclosure of such information would be harmful to the Producing Party or may cause the Producing Party to violate the federal securities laws or the rules and regulations of the New York Stock Exchange.

4. Any document or portion thereof, including any transcript, exhibit, answer to interrogatory, information revealed during depositions upon oral or written examination, other discovery request or response, affidavit, declaration, brief, memorandum, or any other paper and any physical object, recording, or thing that a Producing Party believes to contain Confidential or Attorneys' Eyes Only information shall be so designated by stamping or otherwise applying on each page containing Confidential or Attorneys' Eyes Only information with the designation "Confidential" or "Attorneys' Eyes Only," in which case such designated document and the information contained therein shall be treated in accordance with the terms of this Protective Order. Nothing in this Protective Order constitutes an admission of a Party that any information designated as "Confidential" or "Attorneys' Eyes Only" by a Producing Party does in fact constitute a trade secret or proprietary information or constitutes an agreement or admission with respect to the competency, relevance, or materiality of any such information.

5. All Confidential or Attorneys' Eyes Only information not reduced to documentary, tangible, or physical form or which cannot be conveniently designated pursuant to Paragraph 4 shall be designated by the Producing Party by informing all Receiving Parties in writing.

6. "Qualified Person," as used herein, is limited to the following categories of persons:

a. Outside attorneys and in-house counsel working on this action, and any paralegal, secretarial, photocopying, document imaging, data entry, data processing, drafting, graphics, stenographic reporting, or clerical personnel working under direct supervision of such counsel;

b. Subject to the conditions set forth in paragraphs 10 and 11, any independent technical or financial expert, independent consultant, or independent testing personnel and their employees serving any attorneys identified in Paragraph 6(a) for the purposes of this case, who shall first have executed the Undertaking annexed hereto as Exhibit A;

c. Any independent paralegal, secretarial, photocopying, document imaging, data entry, data processing, drafting, graphics, stenographic reporting or clerical personnel serving such attorneys identified in Paragraph 6(a) for the purposes of this case;

d. Any court reporter or videographer employed or retained by a party for the purposes of transcribing and/or recording a deposition or inspection of premises;

e. The Court and its personnel; f. Any person indicated on the face of a document as having written or received such document during the course of his or her employment or consultancy; and, at trial or deposition, any current or former employee of the Producing Party ("Witness"), provided that the Producing Party's ...


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