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Martinez v. Schlumberger Technology Corp.

United States District Court, D. New Mexico

April 12, 2017

SAUL MARTINEZ, on Behalf of Himself and on Behalf of All Others Similarly Situated, Plaintiff,
v.
SCHLUMBERGER TECHNOLOGY CORPORATION, Defendant.

          CONFIDENTIALITY AND PROTECTIVE ORDER

          LOURDES A MARTÍNEZ UNITED STATES MAGISTRATE JUDGE

         Defendant Schlumberger Technology Corp. (“STC”) assert that certain documents produced by Defendants in this action contain sensitive confidential, proprietary, and valuable trade secrets and information, the disclosure of which could be harmful to Defendants' businesses and affect their competitiveness and the confidentiality of which outweighs the public's interest in full access to all documents related to this Litigation. Further, Defendants maintain numerous other records containing confidential information concerning employees, the disclosure of which could be adverse to the employees. However, some of the above-described records may contain information relevant to Plaintiff Saul Martinez Jr.'s (“Plaintiff”) claims and, thus, be discoverable. Accordingly, the Court orders that the following provisions are in place concerning the documents, discovery responses, depositions and other items produced, exchanged or otherwise utilized in this lawsuit:

         Definitions

         1. The terms defined in Paragraph 1 shall have the meaning provided. Defined terms may be used in the singular or plural.

1.1. “Producing Party” means the Party or person who produces or who is asked to produce documents or information that the Party or person considers to be Confidential or Highly Confidential.
1.2. “Designating Party” means the Party who produces or who receives documents that it considers to be Confidential or Highly Confidential and provides notice to the other Parties of the designation.
1.3 “Receiving Party” means the Party receiving or requesting the production of documents or information designated as Confidential or Highly Confidential.
1.4 “Objecting Party” means the Party receiving the production of documents or information designated as Confidential or Highly Confidential and who objects to the designation of documents as such.
1.5. The “Litigation” means the lawsuit captioned above, including all discovery proceedings, hearings, preparation and pre-trial, trial, and post-trial activities related thereto.
1.6. “Litigation Documents” means all pleadings, motions, affidavits and related papers, answers to interrogatories, all documents produced or exchanged in the course of discovery, settlement negotiations, trial preparation or trial, and all transcripts of testimony given in depositions, in hearings or at trial in connection with the Litigation.
1.7. The “Parties” shall mean the Parties to this Litigation, current, past and future: Plaintiff Saul Martinez Jr., other named Plaintiffs, opt-in/putative plaintiffs, STC, Schlumberger Limited (“SLB”), and all agents thereof.
1.8. “Non-party” shall mean any entity or individual that is not (currently or previously) a party to this Litigation.

Confidential and Highly Confidential Information

         2. The terms “Confidential Information” and “Highly Confidential Information” shall have the meaning provided below:

2.1. “Confidential Information” means all information, whether or not embodied in a document or other physical medium, which the Designating/Producing Party believes in good faith lends to it a competitive advantage over others who do not possess such information, as well as confidential private, or personal information relating to any individual Party, employee, or former employee of the Party, which the Designating/Producing Party would not normally reveal to third parties except in confidence, or has undertaken with others to maintain in confidence. Confidential Information includes any data, summary, abstract, compilation, or information obtained, derived, or generated from Confidential Information. Documents designated as “Confidential Information” must include trade secrets, confidential research, development, or commercial information, or confidential information related to business operations, finances, employees, or medical condition as described in the Federal Rules of Civil Procedure Rule 26(c)(1)(G).
2.2. “Highly Confidential Information” means all information, whether or not embodied in a document or other physical medium, which the Designating/Producing Party believes in good faith contains or reflects proprietary information, trade secrets or competitive or commercial information of a sensitive nature that disclosure to another party or an employee or officer of such other party may cause competitive injury. Highly Confidential information includes any data, summary, abstract, compilation, or information obtained, derived, or generated from Confidential Information. Documents designated as “Highly Confidential Information” must include trade secrets, confidential research, development, or commercial information, or confidential information related to business operations or finances, as ...

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