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Ronald Brown; Charles Detwiler; and Dwight Hicks; On Behalf of v. National Football League Players Association

March 26, 2012

RONALD BROWN; CHARLES DETWILER; AND DWIGHT HICKS; ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION, A VIRGINIA CORPORATION; AND NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED, D/B/A NFL PLAYERS, A VIRGINIA CORPORATION, DEFENDANTS.



The opinion of the court was delivered by: Hon. Frederick F. Mumm United States Magistrate Judge

DISCOVERY MATTER assigned to Magistrate Judge Frederick F. Mumm [PROPOSED] PROTECTIVE ORDER

[Stipulated Protective Order Filed Concurrently]

[PROPOSED] ORDER

Pursuant to the parties' Stipulated Protective Order filed on March 23, 2012, the Court HEREBY ORDERS the entry of the following Protective Order:

I.PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are 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 prosecuting this litigation or, upon agreement by the parties or a court order, any other related litigation would be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Protective Order, which is substantially-similar to the protective order modified and entered by the Court in the related action, Grant v. National Football League Players Association, No. CV11-03118 RGK (FFMx), on December 15, 2011 (ECF No. 45).

The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential. The parties further acknowledge, as set forth in Section 10 (FILING PROTECTED MATERIAL), below, that this Stipulated Protective Order creates no entitlement to file confidential information under seal; Local Rule 79-5 sets forth the procedures that must be followed and reflects the standards that will be applied when a party seeks permission from the Court to file material under seal.

II.DEFINITIONS

2.1 Challenging Party: a Party or non-party that challenges the designation of information or items under this Order.

2.2 "Confidential" Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under Federal Rule of Civil Procedure 26(c).

2.3 Counsel (without qualifier): Outside Counsel and House Counsel (as well as their support staffs).

2.4 Designating Party: a Party or non-party that designates information or items that it produces in Discovery Material as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only."

2.5 Disclose or Disclosure: allowing or failing to take reasonable steps under the circumstances to prevent: (1) visual inspection of a designated document (or any summary, description, abstract, or index thereof) by an individual not authorized under this order; or (2) any communication that reveals, reflects, paraphrases, conveys, or otherwise discloses the substance or form of all or any information that has been part of a designated document (or any summary, description, abstract, or index thereof).

2.6 Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its Counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party's and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party. This definition includes a professional jury or litigation consultant retained in connection with this litigation.

2.8 "Highly Confidential -- Attorneys' Eyes Only" Information or Items: very sensitive "Confidential Information or Items" whose Disclosure to another Party or non-party would create a substantial risk of serious injury either to the Producing Party or a non-party (e.g., a retired player or licensee) that could not be avoided by less restrictive means.

2.9 House Counsel: attorneys who are employees of a Party.

2.10 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action, and are counsel of record in this action.

2.11 Party: any party to this action, including the party's consultants, retained Experts, and Outside Counsel (and their support staff), and, where the party is a corporation or organization, its officers, directors, and employees.

2.12 Producing Party: a Party or non-party that produces Discovery Material in this action.

2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; obtaining, organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors.

2.14 Protected Material: any Discovery Material that is designated as "Confidential" or as "Highly Confidential -- Attorneys' Eyes Only."

2.15 Receiving Party: a Party that receives Discovery Material from ...


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