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Wilson v. Bright Horizons Children's Center LLC

United States District Court, S.D. Texas, Houston Division

January 4, 2018

JACKLYN WILSON, Plaintiff,
v.
BRIGHT HORIZONS CHILDREN'S CENTER LLC, Defendant.

          Chukwudi Egbuonu LAW OFFICE OF CHUKWUDI EGBUONU Attorney for Plaintiff

          Danielle K. Herring LaDelle Davenport, LITTLER MENDELSON, P.C. Attorneys for Defendant.

          AGREED PROTECTIVE ORDER

          GRAY H. MILLER, UNITED STATES DISTRICT JUDGE.

         Plaintiff Jacklyn Wilson ("Wilson" or "Plaintiff) and Defendant Bright Horizons Children's Centers LLC ("Defendant") to the above-styled action (the "Lawsuit" or the "Litigation") are engaged in discovery that may involve requests for disclosure of information considered by one or more parties to be confidential or proprietary business information and/or confidential personal information.

         To facilitate the disclosure of documents and information, the parties, through their respective attorneys of record, have jointly moved the Court to enter an Agreed Protective Order to protect the confidentiality of information that may be produced or disclosed. The Court, having considered this issue, Orders that:

         1. Designation of Confidential Materials.

         The parties to this Litigation may designate as "Confidential" any documents, deposition testimony, or other tangible thing which contains confidential information, including but not limited to non-public personal, medical, or financial information; sensitive personnel information regarding Defendants' employees, former employees, and/or job applicants; non-public financial and/or customer information; trade secrets or non-public, confidential proprietary information belonging to Defendants or related entities. For documents or other tangible things, such designation shall be made by stamping the document or things as "Confidential" prior to delivering a copy of same to the opposing party. For deposition testimony, such designation shall be made by identifying specific testimony as "Confidential" on the record at the deposition.

         2. Subsequent Designation of Confidential Materials.

         Any party may designate any document, deposition testimony, or other tangible thing as containing confidential information which has been previously produced or transcribed without such designation or that has been produced or transcribed by another party and was not designated as containing confidential information at the time produced or transcribed. Notice of such post-production designation shall be given in writing to all parties to whom such materials have previously been furnished. For documents or other tangible things, such post-production designation should be made within thirty (30) calendar days after the document or other tangible thing has been produced. For deposition transcripts, such post-production designation should be made within thirty (30) days after the official deposition transcript has been received. From the time such post-production designation is made, it shall have the same effect as if each individual item designated on a post-production basis was in fact marked as set forth in paragraph 1 above at the time of the production.

         3. Challenges to Designation.

         A party may challenge the designation of a particular document or matter as "Confidential" by motion to the Court. At the hearing on such motion, the party seeking the confidentiality of a document or documents or matters shall have the burden of proving good cause for the entry of an order maintaining the confidentiality of the matter.

         4. Maintenance of Confidential Matters.

         Any portion of the foregoing documents or matters designated as "Confidential, " until further ordered by the Court, shall be maintained in strict confidence by the attorneys for the parties, shall be used solely in the preparation or trial of this Lawsuit and shall be disseminated or disclosed only to the following persons:

a. Counsel employed by or retained by a party for this Lawsuit and their staff;
b. Any Party and/or officers, directors, representatives and employees of a party (including in-house counsel) who are ...

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