Automated Summary
Contract Name
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER
Contract Type
Stipulated Confidentiality Agreement and Protective Order
Legal Area
Litigation & Dispute Resolution
Contract Date
2025 November 18
Effective Date
2025 November 18
Parties
- Nadir Lahmeur (Defendant)
- SGD Pharma Packaging, Inc. (Plaintiff)
Background
The parties to the action request a protective order to safeguard nonpublic and competitively sensitive information during discovery. The parties agree to the terms of the confidentiality agreement, and the court finds good cause for issuing the order.
Scope of Work
The scope of work involves the stipulated confidentiality agreement and protective order between the parties, requiring proper designation of confidential discovery materials, restricted disclosure to specific individuals and entities (including counsel, experts, and court personnel), use of non-disclosure agreements for certain recipients, and the obligation to return or destroy all confidential materials within 60 days of the case's conclusion.
Term
The confidentiality obligations remain in effect for 60 days after the final disposition of the action, including all appeals, and the protective order continues to bind all parties even after the litigation concludes.
Confidentiality Clause
The confidentiality clause prohibits disclosure of Confidential Discovery Material except as permitted under the Order. Confidential material includes financial information, non-public company ownership details, business plans, personal information, and court-designated confidential info. Producing parties must mark confidential portions and provide redacted copies. Recipients may only share with counsel, insurers, experts, and court personnel, requiring signed Non-Disclosure Agreements for third parties.
Data Protection Clause
N/A
Termination Clause
Within 60 days of the final disposition of this action—including all appeals—all recipients of Confidential Discovery Material must return or destroy such material, including all copies. Attorneys specifically retained for this action may retain an archival copy of documents containing Confidential Discovery Material, which remains subject to this Order. The Order survives litigation termination and continues to bind all parties who received Confidential Discovery Material.
Dispute Resolution Clause
Parties may object to confidentiality designations by serving written notice with particularity before trial. Unresolved disputes are addressed to the Court in accordance with Rule 2(C) of the Court's Individual Rules of Practice. Similarly, requests for additional disclosure limits must follow this process. The Court retains jurisdiction to enforce obligations and impose sanctions for contempt.