RODNEY K. MILLEN, individually and as Trustee of the Rodney K. Millen Trust, dated September 7, 1994, Plaintiff,
TEXTRON, INC., a Delaware corporation, Defendant. TEXTRON INC., a Delaware company, Counterclaimant,
RODNEY K. MILLEN, individually and as Trustee of the Rodney K. Millen Trust, dated September 7, 1994, Counterdefendant. TEXTRON INC., a Delaware corporation, Third Party Plaintiff,
SHELLEY CAMPBELL, individually, Third Party Defendant.
PROTECTIVE ORDER ORDER
JEAN P. ROSENBLUTH, Magistrate Judge.
In light of the Stipulation of the parties filed herewith, and good cause appearing therefore, IT IS HEREBY ORDERED as follows:
Any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).
B. Disclosure or 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.
C. "Confidential" Information or Items
Any information produced in this litigation in any form that any party or nonparty reasonably believes to contain proprietary, competitively sensitive, trade secret, or private employee information.
D. Receiving Party
A Party that receives Disclosure or Discovery Material from a Producing Party.
E. Producing Party
A Party or non-party that produces Disclosure or Discovery Material in this action.
F. Designating Party
A Party or non-party that designates information or items produced in disclosures or in responses to discovery as "Confidential."
G. Protected Material
Any Disclosure or Discovery Material that is designated as "Confidential."
H. Outside Counsel
Attorneys who are not employees of a Party but who are retained to represent or advise a Party or non-party in this action.
I. House Counsel
Attorneys who are employees of a Party or non-party.
J. Counsel (without qualifier)
Outside Counsel and House Counsel (as well as their support staffs).
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. "Expert" also shall mean an employee of a party who is retained as an expert in this action. This definition includes a professional jury or trial consultant retained in connection with this litigation.
L. Professional Vendors
Persons or entities who provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or ...