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Robinson v. Gilliard

United States District Court, D. South Carolina

May 16, 2018

Corey Jawan Robinson #294233, Plaintiff,
v.
Officer/Sergeant Mr. Gilliard, Defendant.

          Chadwick Devlin Attorney for the Plaintiff.

          Elloree Ganes Attorney for the Defendant.

          Christopher R. Antley Attorney for the South Carolina Department of Corrections.

          CONSENT CONFIDENTIALITY AND PROTECTIVE ORDER

         The parties to this Consent Confidentiality and Protective Order (“parties”) have stipulated that the South Carolina Department of Corrections (“SCDC”) restricted policies that are the subject of the Plaintiff's Rule 45 subpoena should be treated as confidential, and have agreed to the terms of this order; accordingly, it is on this 16th day of May, 2018, ORDERED:

         1. Scope. All documents (whether in paper or electronic form) produced in by SCDC in response to the Plaintiff's Rule 45 subpoena to SCDC (hereinafter collectively “the subpoenaed policies”) shall be subject to this Order concerning confidential information as set forth below.

         2. Form and Timing of Designation. Confidential documents shall be so designated by placing or affixing the word “CONFIDENTIAL -- ATTORNEY'S EYES ONLY” on the document in a manner which will not interfere with the legibility of the document. Documents shall be designated “CONFIDENTIAL - ATTORNEY'S EYES ONLY” prior to, or contemporaneously with, the production or disclosure of the documents. Inadvertent or unintentional production of documents without prior designation as confidential shall not be deemed a waiver, in whole or in part, of the right to designate documents as confidential as otherwise allowed by this Order.

         3. Documents Which May be Designated Confidential. All policy documents that SCDC produces in response to the Plaintiff's Rule 45 subpoena will be designated as “CONFIDENTIAL - ATTORNEY'S EYES ONLY.”

         4. Depositions. For the purposes of depositions only, documents designated as “CONFIDENTIAL - ATTORNEYS' EYES ONLY” may be discussed with deponents and entered as sealed exhibits to the deposition without losing their confidential designation. The Plaintiff may not see these policy documents, even during a deposition. Any other party who is present at the deposition may see these documents during the deposition and assist their attorney in the deposition. However, the party may not take notes based on the contents of a document designated as “CONFIDENTIAL - ATTORNEYS' EYES ONLY”, and once the deposition is over, the party may not retain a copy of, or otherwise see, documents bearing this designation unless SCDC consents in writing or the Court enters an order to the contrary.

         5. Protection of Confidential Material.

a. General Protections. Documents designated “CONFIDENTIAL - ATTORNEY'S EYES ONLY” under this Order shall not be used or disclosed by the parties or counsel for the parties or any other persons identified below (¶ 5.5(b.)) for any purposes whatsoever other than preparing for and conducting the litigation in which the documents were disclosed (including any appeal of that litigation).
b. Limited Third Party Disclosures. The parties and counsel for the parties shall not disclose or permit the disclosure of any documents designated “CONFIDENTIAL - ATTORNEY'S EYES ONLY” under the terms of this Order to any other person or entity except as set forth in subparagraphs (i)-(iii) below, and then only after the person to whom disclosure is to be made has executed an acknowledgment (in the form set forth at Attachment A hereto), that he or she has read and understands the terms of this Order and is bound by it. Subject to these requirements, the following categories of persons may be allowed to review documents which have been designated “CONFIDENTIAL - ATTORNEY'S EYES ONLY” pursuant to this Order:
i. counsel and employees of counsel for the parties who have responsibility for the preparation and trial of the lawsuit - these individuals will be exempt from signing the acknowledgement described above;
ii. other persons only upon consent of the producing party;
iii. upon order of the court and on such conditions as are agreed ...

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