Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Edwards v. Pennsylvania Human Relations Commission

United States District Court, M.D. Pennsylvania

December 3, 2019

JOANN EDWARDS Plaintiff
v.
PENNSYLVANIA HUMAN RELATIONS COMMISSION Defendant

          Patrick G. Murphy Esquire Murphy & Associates Attorney For Plaintiff

          Allison L. Deibert Esquire Deputy Attorney Generel Office Of Attorney Generel Attorney for defendant

          JOINT CONFIDENTIALITY AGREEMENT

         The parties to this action, Plaintiff JoAnn Edwards ("Plaintiff') and Defendant Pennsylvania Human Relations Commission ("Defendant") by their respective counsel, hereby agree as follows:

         1. Defendant and Plaintiff stipulate that the litigation in the above-captioned matter will involve discovery of confidential information about current and/or former employees who are not parties to this litigation and may concern other matters of a sensitive nature coming before Defendant.

         2. Defendant and Plaintiff agree that the above-identified confidential information has value only to the parties in this matter, and that the public has no interest in such information.

         3. Defendant and Plaintiff agree that the misuse or unnecessary dissemination of the above-identified confidential information could violate the privacy of third parties and cause undue embarrassment to current and/or former employees and/or other members of the public.

         WHEREFORE, Defendant and Plaintiff hereby stipulate and agree, for the above stated reasons, as follows:

         1. Defendant and Plaintiff may designate as "CONFIDENTIAL" any document, testimony, information or material disclosed through formal or informal discovery or otherwise in the course of this litigation as hereinafter set forth in Paragraphs 2, 3, and 4. Such designation shall subject the information produced or provided under said designation to the provisions of this Confidentiality Agreement.

         2. Any writing produced by any party or person in this litigation may be designated as "CONFIDENTIAL" by Defendant and Plaintiff by stamping the words "CONFIDENTIAL" on the face of the writing. Alternatively, a party may designate any writing as "CONFIDENTIAL" by identifying such document(s) by Bates Stamp number and designating it/them as "CONFIDENTIAL" in a cover letter addressed to the opposing party's counsel and accompanying the production of such document(s).

         3. Defendant and Plaintiff may designate deposition testimony or any portion of deposition testimony as "CONFIDENTIAL" by advising the reporter and counsel of such designation during the course of the deposition or at any time thereafter. Whenever any writing designated as "CONFIDENTIAL" is identified as an exhibit in connection with testimony given or with any document filed with the Court in this case, it shall be so marked.

         4. Defendant and Plaintiff may designate as "CONFIDENTIAL" specific responses to information requests by labeling the specific response "CONFIDENTIAL."

         5. Whenever any writing, testimony, information or material designated as "CONFIDENTIAL" is used or submitted to the Court in conjunction with any filing or proceeding in this litigation, it shall be so marked. Any party to this litigation shall have the right to designate as "Confidential" and subject to this Order any information, document, or thing, or portion of any document or thing: (a) that contains trade secrets, competitively sensitive technical, marketing, financial, sales or other confidential business information, or (b) that contains private or confidential personal information, (c) that contains information received in confidence from third parties, or (d) which the producing party otherwise believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure and Local Civil Rule.

         6. Except upon prior written consent of the party asserting "CONFIDENTIAL" treatment or upon further order of a court of competent jurisdiction, documents, testimony, information or material designated as "CONFIDENTIAL" shall be held in strict confidence and shall be used solely for the purposes of prosecution or defense of this litigation. Access to "CONFIDENTIAL" documents, testimony, information or material shall be limited to:

(a) Counsel for the respective parties and co-counsel (and employees of said counsel who are assisting in the prosecution ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.