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Verso Paper LLC v. Hireright

November 23, 2011

VERSO PAPER LLC, PLAINTIFF,
v.
HIRERIGHT, INC., DEFENDANT.



The opinion of the court was delivered by: The Honorable Robert N. Block United States Magistrate Judge

ASSIGNED FOR ALL PURPOSES TO JUDGE DAVID O. CARTER

STIPULATION FOR AND [PROPOSED] PROTECTIVE ORDER

Plaintiff Verso Paper LLC ("Verso Paper") and Defendant Hireright, Inc. ("HireRight"), by and through their respective counsel of record, hereby enter into the following stipulation:

STIPULATION FOR PROTECTIVE ORDER

Scope

1. This protective order shall govern all documents and information produced or disclosed in the above-captioned action (the "Action") by any party to the Action or third party from whom documents or information is sought (the "Designating Party") to the other party or parties ("the Receiving Party") that are designated as "Confidential Information" or "Attorneys Eyes Only Material." This protective order applies to all current and later-joined parties and any third parties producing and/or receiving documents in the Action, including without limitation Verso Paper, HireRight and National Union Fire Insurance Company of Pittsburgh PA ("National Union").

Good Cause Statement

2. Based on the claims at issue in this matter, the parties will likely request private and confidential financial information during the discovery process, including financial information related to the parties and/or third parties. Documents containing or making reference to confidential financial information are considered private and confidential and would likely cause significant harm to that party and/or infringe upon its ability to compete if such information was made available or accessible publicly and/or to the party's competitors.

3. Based on the claims at issue in this matter, the parties will likely request trade secret and/or otherwise proprietary, confidential or sensitive business information related to either party's business operations that would likely cause significant harm to that party and/or infringe upon its ability to compete if such information was made available or accessible publicly and/or to the party's competitors.

4. Based on the claims at issue in this matter, the parties will likely request information about current, past, or prospective employees that is of a confidential or private nature, including, but not limited to, current or former employees' contact information, wage information and job performance-related documentation. Such information is considered private and confidential and could violate an individual's privacy rights if it was made publicly available.

5. For the reasons set forth above, good cause exists for a protective order that will allow the parties to produce documents and information that they consider confidential, private, sensitive and/or documents that contain trade secrets while taking appropriate steps to protect the confidential, private, sensitive and/or trade secret nature of the documents and information.

Confidential Information

6. "Confidential Information" means any information contained in a document that is stamped with a "Confidential" designation. Confidential Information may include, but is not limited to:

(a) Private and confidential financial information related to the parties and/or third parties; or

(b) Proprietary, confidential or sensitive business information or information that otherwise is protected as a trade secret; or

(c) Information about current, past, or prospective employees that is of a confidential or private nature, including, but not limited to, current or former employees' contact information, wage information and job performance-related documentation.

7. "Attorneys Eyes Only Material" means any information contained in a document that is stamped with an "Attorneys Eyes Only" designation. Attorneys Eyes Only Material may include, but is not limited to highly confidential or sensitive business information that could cause financial harm to either party if disseminated to the public or a competitor.

Restrictions On Disclosure of Confidential Information and Attorneys Eyes Only Material

8. Subject to paragraph 10, and excepting the Court and any Court personnel, Confidential Information produced under this protective order shall not be disclosed by any person who has received such Confidential Information through this Action to any other person except to:

(a) Attorneys of record for the parties and their respective associates, paralegals, clerks and employees involved in the conduct of this Action, and either party's in-house attorneys and attorneys employed by its corporate parents and/or corporate affiliates and their respective paralegals, clerks and employees;

(b) Any outside consultant or expert and any employees thereof who would, in the course and scope of their employment or engagement, handle the at-issue ...


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