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Extracted Text (OCR)
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 3 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 4 of 7
h. other persons by written agreement of the parties.
Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel, persons employed by counsel, Court
Personnel and stenographic reporters), counsel] shall provide such person with
a copy of this Protective Order and obtain from such person a written
acknowledgment stating that he or she has read this Protective Order and
agrees to be bound by its provisions. Al] such acknowledgments shall be
retained by counsel and shall be subject to in camera review by the Court if
good cause for review is demonstrated by opposing counsel.
Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: “CONFIDENTIAL.” Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To the extent practical,
the respective legend shall be placed near the Bates number.
Designation of a document as CONFIDENTIAL INFORMATION shall
constitute a representation that such document has been reviewed by an
attorney for the designating party, that there is a valid and good faith basis for
such designation, made at the time of disclosure or production to the receiving
party, and that disclosure of such information to persons other than those
permitted access to such material would cause a privacy harm to the
designating party.