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Hempel v. Cydan Development, Inc.

United States District Court, D. Maryland

October 18, 2018

ADDISON HEMPEL, CASSIDY HEMPEL, CHRISTINE HEMPEL, HUGH HEMPEL, and SOLUTION THERAPEUTICS, Plaintiffs,
v.
CYDAN DEVELOPMENT, INC., CYDAN II, INC., VTESSE, INC., SUCAMPO PHARMACEUTICALS, INC., and DOES I-X and ROE CORPORATIONS I-V, inclusive, Defendants.

          David C. O'Mara THE O'MARA LAW FIRM, P.C. JOSHUA L. SEIFERT PLLC Joshua L. Seifert, Esq, Pro Hac Vice SLARSKEY LLC David COUNSEL FOR PLAINTIFFS Slarskey, Esq COUNSEL FOR PLAINTIFFS

          E. Leif Reid LEWIS ROCA ROTHGERBER CHRISTIE LLP Paul B. Gaffney (pro hac vice) Jessica Bodger Rydstrom (pro hac vice) Benjamin M. Stoll (pro hac vice) Amanda J. Cox (pro hac vice) WILLIAMS & CONNOLLY LLP COUNSEL FOR DEFENDANTS

          FIRST AMENDED STIPULATION AND PROTECTIVE ORDER

         The parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for issuance of an appropriately-tailored confidentiality order governing this action, it is therefore hereby

         ORDERED that any person subject to this First Amended Stipulation and Protective Order (“this Order”)-including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order-shall adhere to the following terms:

         1. Scope. This Order shall govern all information produced in connection with this action in any form to any persons, including, without limitation, deposition testimony and exhibits, testimony taken at a hearing or other proceeding, interrogatory answers, documents and other discovery materials (whether produced informally or in response to interrogatories), requests for admissions, requests for production of documents, or other formal methods of discovery. This Order shall also govern all information produced, exchanged, or served in this action pursuant to required disclosures under any federal procedural rule, and any supplementary disclosures thereto.

         2. Confidentiality. Any person subject to this Order who receives from any other person any information of any kind-whether document, testimony, or any other form- provided in the course of this action (“Discovery Material”) that is designated as “Confidential” pursuant to the terms of this Order shall not disclose such Confidential Discovery Material to anyone else except as expressly permitted by this Order.

         3. Definition of “Confidential.” The person producing any given Discovery Material may designate as “Confidential” any Discovery Material or portion of Discovery Material that contains non-public business, commercial, financial, or personal information within the meaning of Fed.R.Civ.P. 26(c)(1)(G), the public disclosure of which is either restricted by law or could, in the good faith opinion of the producing person, adversely affect a person's or entity's privacy interests or obligations or a person's or entity's policy, business, commercial, financial, or personal interests.

         4. Designation Process. With respect to the Confidential portion of any Discovery Material other than deposition and pre-trial transcripts and exhibits, the producing person or that person's counsel may designate such portion as “Confidential” by stamping or otherwise clearly marking as “Confidential” the document or protected portion of the document in a manner that will not interfere with legibility or audibility. Deposition and pre-trial testimony and exhibits may be designated as Confidential either on the record during the deposition or within 5 days of receipt of the transcript.

         5. Designation of Confidential Discovery Material after Production. The failure to designate Discovery Material as Confidential at the time of production shall not constitute a waiver of such designation. At any time prior to the trial of this action, any Discovery Material produced without a “Confidential” designation may be designated by any party as Confidential by informing all parties in writing that the Discovery Material should be treated as Confidential under this Order. Upon receipt of such notice, all parties and persons subject to this Order shall treat such information consistent with the redesignation going forward.

         6. Use of Confidential Information. Each party and all persons bound by the terms of this Order shall use any Discovery Material designated Confidential only in connection with the prosecution or defense of this action, except by consent of the designating and producing parties or by order of the Court; provided, however, that the foregoing shall not apply to Discovery Material that is or becomes part of the public record or otherwise falls under one of the exceptions described below in paragraph 13.

         7. Disclosure of Confidential Information. No. person subject to this Order shall disclose any Discovery Material designated as Confidential to any other person, except:

a. the parties to this action, including their affiliates and their current and former agents and employees who are assisting with or making decisions concerning this action, to the extent deemed reasonably necessary by counsel of record for the purpose of assisting in the prosecution or defense of this action, and provided such persons have first executed the Non-Disclosure Agreement attached to this Order;
b. counsel retained specifically for this action, including any paralegal, clerical, and other assistant employed by such counsel and assigned to this matter; c. the author of the Confidential Discovery Material, and any person indicated on the face of the material as having received a copy of it;
d. any witness called to testify at deposition or any witness whom counsel for a party in good faith believes may be called to testify at trial or deposition in this action, provided such person has first executed ...

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