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In re Syngenta Mass. Tort Actions

United States District Court, S.D. Illinois

August 18, 2016

IN RE SYNGENTA MASS TORT ACTIONS This Document Relates to: Tweet et al.
v.
Syngenta AG et al.,

          PROTECTIVE ORDER

          David R. Herndon United States District Judge.

         For good cause shown under Rule 26(c), the Court enters the following Protective Order:

         I. SCOPE.

         This Protective Order governs the treatment of all documents and other products of discovery, all information derived or extracted therefrom and including, but not limited to, all copies, excerpts or summaries thereof of any depositions, deposition exhibits, interrogatory answers, responses to requests for admission and any other discovery authorized by the Federal Rules of Civil Procedure, as well as any other disclosed information (collectively “Discovery Material”) produced by any party or non-party (“Producing Party”) in the above-captioned proceedings (the “Action”). This Protective Order governs Confidential and Highly Confidential Discovery Materials.

         II. LIMITATION ON USE.

         Discovery Material may be used solely for the prosecution, defense, appeal and/or settlement of litigation of the Action, and the enforcement of insurance rights with respect to this Action, and may be disclosed only under the circumstances and to the persons specifically provided for in this or subsequent Court Orders, or with the prior written consent of the Producing Party with respect to specifically identified Discovery Material and may not be used for any other purpose, including but not limited to,

A. The prosecution or defense of other actions not subject to this Protective Order;
B. In any proceeding before or application to any government agency;
C. In client solicitation or attorney advertising materials;
D. Disclosure to media or competitors of parties to the Action; or
E. Any purpose other than the prosecution or defense of this Action.

         III. DEFINITION OF CONFIDENTIAL DISCOVERY MATERIAL.

         Any Producing Party may designate as “Confidential” any Discovery Material that it believes in good faith contains legally protectable information in accordance with Rule 26(c) of the Federal Rules of Civil Procedure, such as:

A. Non-public or personal information regarding the identity of and marketing information regarding customers, growers, elevators, vendors, contractors, suppliers, and other non-parties with whom the parties do business (including Social Security numbers, tax returns, medical, investment, credit and banking information);
B. Proprietary business information and trade secrets, including licensing, distribution, marketing, design, redevelopment, research, test data and manufacturing information regarding products or technology, whether or not previously or currently marketed or under development;
C. Clinical studies;
D. Competitor and competitor product or technology information, including third party product or technology licenses;
E. Production information, including, but not limited to trade secrets or confidential research, development, or commercial information;
F. Financial Information not publicly filed with any federal or state regulatory authority;
G. Information submitted to the EPA, FDA, USDA, or any other governmental agency, that under applicable regulations is exempt from disclosure under the Freedom of Information Act;
H. Information that a party obtained from another entity and which the party is required to keep confidential pursuant to an agreement entered into with such entity in the regular course of business;
I. Information contained in insurance policies that may cover this action;
J. Personnel compensation, evaluations or other private employment information; or
K. Confidential or proprietary information about affiliates, parents, subsidiaries or third parties with whom the Parties to this action have had or have endeavored to have business relationships.

         Information or documents that are available to the public may not be designated as Confidential. All Discovery Material so designated shall be referred to in this Protective Order as “Confidential Discovery Material” and shall be handled in strict accordance with the terms of this Protective Order.

         IV. DEFINITION OF HIGHLY CONFIDENTIAL DISCOVERY MATERIAL.

         Any Producing Party may designate any Discovery Material as “Highly Confidential” if such party in good faith believes that such Discovery Material contains Highly Confidential information. All Discovery Material so designated shall be referred to in this Protective Order as “Highly Confidential Discovery Material” and shall be handled in strict accordance with the terms of this Protective Order. Highly Confidential Discovery Material means information not otherwise publicly available that the Producing Party believes, in good ...


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