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Price v. U.S. Bank, N.A.

United States District Court, D. Montana, Billings Division

March 7, 2018

R. MICHAEL PRICE, Plaintiff,
v.
US BANK, N.A., Defendant.

          By Michael F. McGuinness James A. Patten Patten, Peterman, Bekkedahl & Green, PLLCATTORNEYS FOR PLAINTIFF

          By Jennifer Hadley Catero Steven D. Jerome Snell and Wilmer, L.L.P.

          Michelle M. Sullivan Sullivan Miller Law, PLLC ATTORNEYS FOR DEFENDANT

          AGREED PROTECTIVE ORDER

          SUSAN P. WATTERS U.S. DISTRICT COURT JUDGE

         Upon consideration of Plaintiff s Motion requesting entry of an Agreed Protective Order (Doc. 41), the Court has found that certain confidential information may be produced during the course of discovery in this case, and there is good cause pursuant to Federal Rule of Civil Procedure 26(c) to restrict the dissemination of confidential information as set forth below.

         IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED:

         1. That documents and things considered by a party or a nonparty from whom discovery is sought to contain either (a) documents reflecting confidential information of non-parties, such as personnel records (b) financial information that is business confidential (c) business confidential sales and customer information (d) non-public, proprietary or confidential corporate and strategic planning information (e) personal income or tax information or (g) any other person or business information that is of a highly sensitive or confidential nature may be marked "CONFIDENTIAL" and shall generally be referred to as "Confidential Information."

         2. No party or nonparty shall designate material as "CONFIDENTIAL" unless counsel for the producing party or nonparty believes in good faith the designated material is entitled to protection under Federal Rule of Civil Procedure 26(c).

         3. With respect to all documents and things produced by a producing party, whether a party to this action or a nonparty, for inspection and copying and which are designated as "CONFIDENTIAL" by the producing party, the documents and things, and the information contained therein, shall be kept confidential, and shall not be communicated in any manner, either directly or indirectly, to any person or other entity other than:

         (a) The outside counsel of record in this action and their respective associates, clerks, legal assistants, stenographic and support personnel, and other employees of such outside counsel (collectively referred to as "outside counsel");

         (b) Those employees and agents of the receiving party having a need to know without written permission from the producing party or further order of this Court;

         (c) Independent experts and consultants, and the employees of such experts and consultants who are assisting them, retained or consulted by counsel of record for any party for the purpose of assisting counsel in the litigation;

         (d) Third party entities, and the employees of said third party entities, retained by the outside counsel to provide support services in this action;

         (e) The person who is the author or addressee of such document or thing, people copied thereof, or the designated representative of any corporation or other entity with whom such ...


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