DOJ-OGR-00002386.pdf

--- Page 1 --- **Document Header:** * Case 1:19-cv-09339-AJN Document144-8 Filed 03/04/28 Page 9 of 28 **Page Content:** * b. persons regularly employed or associated with the attorneys actively working on this case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case; * c. the parties; * d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case; * e. the Court and its employees ("Court Personnel") in this case; * f. stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; * g. deponents, witnesses, or potential witnesses; and * h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen such Protected Material; and * i. any other persons by written agreement of the parties or by Order of a Court of competent jurisdiction. * 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person a written acknowledgment stating that he or she has read this Protective Order and **Footer:** * DOJ-OGR-00002386