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LANGROCK SPERRY
& Woot. LLP
Case 2:05-cv-00212-wks Document46 Filed 08/04/2006 Page 1 of 4
STIPULATED PROTECTIVE ORDER
NOW COME the undersigned parties and hereby stipulate as follows:
1. That certain of the documents being produced by Defendant EPS, Inc. to the Plaintiff's counsel in connection with discovery in this matter contain confidential, proprietary, and valuable information (the “Confidential Documents”);
2. That before producing the Confidential Documents, Defendant’s counsel will clearly mark on the face of the documents their confidential status;
3. That the Confidential Documents are to be used for purposes of this litigation only, and for no other purpose;
4. That the Plaintiff himself not be given copies of the Confidential Documents for his own possession, although he is free to inspect them in counsel’s office;
5. That neither the Plaintiff nor his counsel will disclose the Confidential Documents nor any information contained therein to anyone before giving 7 business days prior notice of their intent to do so. Upon receipt of that notice, Defendant will either consent to re-disclosure of the Confidential Documents subject to the provisions of J 7 below, or object to such re-disclosure. If the parties cannot agree to the terms of Plaintiff's or his
U.S. DISTRICT COURT
DISTRICT OF VERNON
UNITED STATES DISTRICT COURT Filen FOR THE EY DISTRICT OF VERMONT C06 ALS Yam g 26 CLERK U.S. EX REL. ROBERT HARRIS, BY - Plaintiff, "DEPUTY Stes fh i cis Civil Action , Vv. Docket No. 2:05-cv-212 EPS, INC. ET AL., Defendant.
i=
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LANGROCK SPERRY
& Woo. LLP
Case 2:05-cv-00212-wks Document 46 ‘Filed 08/04/2006 Page 2of4
counsel’s proposed re-disclosure, Defendant may apply to the Court for a protective order. Until such motion for a protective order is resolved, no disputed re-disclosure may occur.
6. That the Plaintiff's counsel will number all copies of the Confidential Documents, and return each and every copy to Defendant’s counsel at the conclusion of this litigation;
7. That before giving a copy of the Confidential Documents to any other individual pursuant to §5 above, Plaintiff’s counsel must:
a. instruct such other individual not to make any additional copy of the Confidential Documents; b. provide a copy of this Stipulated Protective Order to any such individual; c. advise such individual that s/he may not re-disclose the Confidential Documents to anyone (including the Plaintiff himself) under any circumstances; d. advise such individual that the terms of the Stipulated Protective Order
bind that other individual as well.
8. That this Stipulated Protective Order binds Plaintiff, his counsel, and any other agents of Plaintiff.
9. That any violation of this Stipulated Protective Order will subject the Plaintiff
to preliminary and final injunctive relief, in addition to damages and other available remedies
in equity or law.
Signatures on next page.
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LANGROCK SPERRY
& Woo. LLP
382194. v1
Case 2:05-cv-00212-wks Document46 _ Filed 08/04/2006 Page3of4 DATED at Burlington, Vermont this | day of August, 2006.
LANGROCK SPERRY & WOOL, LLP
XA Lisa B. Shelkrot \ No 210 College gto . Box 721 Burlington, VT 05402- 0721
(802) 864-0217 ve for Defendant EPS, Inc.
DATED at Burlington, Vermont this 2 y of August, 2006. bf Johiy L. Ktanco, Jr.
1]0 Main Street, Suite 08 Burlington, VT 05401-8451 Attorneys for Plaintiff Harris SO ORDERED:
USS. District Court Judge
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Law OFFICES OF JouN L. Franco, Jr.
110 Matn STREET BURLINGTON, VERMONT 05401
Case 2:05-cv-00212-wks Document46 Filed 08/04/2006 Page 4of4 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF VERMONT CIVIL ACTION NO.
2:05 cv 212 UNITED STATES OF AMERICA ex rel. ROBERT HARRIS, Plaintiff EPS, INC., FRED HUTCHINS, and RICK FLETCHER, Defendants Vv. * CERTIFICATE of SERVICE The undersigned certifies that on this date he served the parties’ Stipulated Protective Order by first class mail, postage prepaid upon Lisa B. Shelkrot, Esq.
Langrock, Sperry & Wool P.O. Box 721 Burlington, VT. 95402-0721 Dated at Burlington, Vermont thi n y of Aygust, 2006. |Anted Jghn L. Franco, /Jr.
Counsel to Robert Harris
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