CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDERConfidentiality Agreement • August 3rd, 2018
Contract Type FiledAugust 3rd, 2018Plaintiff United States of America and defendants Douglas S. Waterbury, Carol A. Waterbury, E&A Management Co., and Ontario Realty, Inc. (the “parties”) agree that during the course of discovery it may be necessary to disclose certain confidential information relating to the subject matter of this action. The parties agree that certain categories of such information should be treated as confidential, protected from disclosure outside this litigation, and used only for purposes of prosecuting or defending this action and any appeals. The parties jointly request entry of this proposed Protective Order to limit the disclosure, dissemination, and use of certain identified categories of confidential information, pursuant to Federal Rules of Civil Procedure 5.2(e) and 26(c), and Local Civil Rule 2.2(a).