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Home My WebLink About04-3550 CUMBERLAND COUNTY ADULT PROBATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA Plaintiff VS. CIVIL ACTION - LAW NO. 0'1. 35'~-o CIVILTERM Carlos Ruben Reyes 2521 Gerard Avenue West Lawn, PA 19609 Defendant RE: NO. 0058-2004 CRIMINAL TERM PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in favor of plaintiff, Cumberland County Adult Probation, and against Defendant in the amount of $ 3,855.50 pursuant to 42 Pa. C.S.A. Section 9728 as set forth in the attached statement of certified case costs and fines. Dennis E. Lebo, Clerk of Court U~C~ Date: July 21, 2004 ENTRY OF JUDGMENT AND NOW, this 2.;:/........t day of L7~ ,.21JZ/Y , judgment is entered in favor of the Plaintiff and against the Defendant in the amount set forth above. Attachment cc; Defendant Probation Clerk of Court Curtis R. Long, Prothonotary jJ~d? Carlos Ruben Reyes 2521 GERARD AVENUE West lawn. PA 19609 R AOPC 2123 -2004 Commonwealth of Pennsylvania Court of Common Pleas County of Cumberland 9th Judicial District Itemized Account of Fines, Costs, Fees, and Restitution Dennis E Lebo Clerk of Courts of Cumberland County Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Commonwealth of Pennsylvania v. Carlos Ruben Reyes Docket No: CP-21-CR-0000058-2004 ATJ Administrative Fee (Cumberland) Automation Fee (Cumberland) Catastrophic Loss Fund (Act 24 of 1989) Commonwealth Cost - HB627 (Act 167 of 1992) County Court Costs (Act 204 of 1976) District Attorney (Cumberland) Emergency Medical Services (Act 45 of 1985) Firearm Education and Training Fund (158 of 1994) JCP Non DUI Central Processing Cost (Cumberland) Plea Fee (Cumberland) Sheriff Costs (Cumberland) State Court Cost (Act 204 of 1976) Traffic Report Costs (Cumberland) Total Costs/Fees $1.50 $45.00 $5.00 $60.00 $7.94 $25.80 $17.00 $20.00 $5.00 $8.50 $200.00 $135.00 $1.50 $9.26 $8.00 $549.50 ....................,..........................................................................................................................................................................................,................................................................................................................................. Title 75, Motor Vehicle Total Fines $1,500.00 $1,500.00 ...........................................................................................................................................................................,................................................".................................................,......................................................................... Restitution Total Restitution $1,806.00 $1,806.00 $549.50 Total Costs/Fees AOPC 2123 - 2004 Page 1 012 0712112004 10:48:47AM Total Due Docket No: CP-21-CR-0000058-2004 $1,500.00 $1,806.00 $3,855.50 Total Fines Total Restitution This is to certify that Carlos Ruben Reyes is indebted to the County of Cumberland for the sum of $3,855.50. This is the total of all fines, costs, fees, and restitution accrued in the above-captioned case. Date Lebo, Dennis E, Clerk of Courts A TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle, PA. ThISq~ dayof ~,J,~ ,20M. ~ 'Uf r~'ClerkOftheCourt Cumberland County AOPC 2123 - 2004 Page 2 012 07/21/2004 10:4B:47AM \ t "I , !'-..) --- ...> . , t; l ., " ~ " " ~ .... 1- c~ , ~ p ~ J r., .iRECEIVED SEP 0 7 2005~ HUB GROUP, INC. and HUB CITY TERMINALS LLC, Plaintiffs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYL VANIA v. MARCIA DELANEY No. 05-3550 Defendant. AGREED PROTECTIVE ORDER WHEREAS, during the course of this litigation, the parties hereto may be provided or seek to obtain discovery of information some of which are claimed to relate to or contain trade secrets or other confidential information; WHEREAS, disclosure of such information might be harmful to the parties and/or to the person or entity producing the information; and WHEREAS, however, the parties reserve the right to object to any discovery request that they believe should not require the production of any documents; IT IS HEREBY ORDERED that: I. Scope of Order. This Protective Order ("Order") shall govern the use and disclosure of all alleged confidential, proprietary or trade secret information ("Protected Information") produced by or on behalf of any party or furnished by any person associated with any party on or after the date of this Order in any pleading, deposition, interrogatory, request for admission, document production, subpoena, or any other disclosure or discovery proceeding in this action until order of this Court. Any alleged confidential or proprietary or trade secret information produced in discovery shall only be used for the purposes of preparing for and conducting this action (including any appeals or retrials) and only as provided in this Order. 10946957 item, or thing shall be permitted only to persons properly having access thereto under the terms of this Order. 4. Manner of Designation. a. The designation of documents or other materials shall be made by written notice in the documents or materials by affixing to it, in a manner that shall not interfere with its legibility, the word "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" on all or any part of the document or thing. Wherever practicable, the designation of "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" shall be made prior to, or contemporaneously with, production or disclosure. Documents or information designated as "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" before entry of this Order shall be treated as "CONFIDENTIAL _ ATTORNEYS' EYES ONL Y" or "CONFIDENTIAL" within the meaning of this Order. The non-designating party may challenge any designation of confidentiality in accordance with Paragraph II. b. All deposition transcripts in this action shall be treated by all parties as provisionally protected as "CONFIDENTIAL - ATTORNEYS' EYES ONLY" for a period of fourteen (14) calendar days following receipt of the transcripts. Within the fourteen (14) day period, any party may designate particular portions of a transcript as "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY" information by giving written notice of such designation to every other party to the action. To the extent possible, the party making the designation shall be responsible for assuring those portions of the deposition transcript and exhibits designated "CONFIDENTIAL" or "CONFIDENTIAL _ ATTORNEYS' EYES ONLY" are appropriately bound by the reporter. The parties should avoid designating entire transcripts as "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY" where only a - 3 - 10946957 portion thereof or the exhibits used therewith qualifY for protection under this Order; to the extent reasonably practicable, only such portions or exhibits should be designated. Failure of a party to so designate any particular portion of the transcript establishes that such portion is not subject to this Order. c. In the event that a party is permitted by agreement or by order of this Court to inspect or review documents prior to production, all documents and things produced at such inspection will be considered to be ATTORNEYS' EYES ONLY. At the time documents and things are actually produced, however, an appropriate designation will be placed on each document or thing in accordance with this Protective Order. 5. Use and Access of Confidential Information. a. CONFIDENTIAL - ATTORNEYS' EYES ONLY: Except as set forth herein or in any subsequent order of the Court or by express written consent of counsel of record, no documents, things or information designated as "CONFIDENTIAL _ ATTORNEYS' EYES ONL Y" shall be, directly or indirectly, delivered, exhibited or disclosed to persons other than; (i) the Court; or any Court personnel, including any court reporter or typist recording or transcribing testimony in this action; and (ii) Counsel for the parties in this proceeding and their paralegals, law clerks, and clerical staff who are providing active assistance with this action. "Counsel," as used herein, shall mean outside counsel for the parties who have entered appearances in this case and other lawyers in their respective law firms who are directly involved in this litigation, but not corporate counsel for any of the parties; and (iii) any person identified from the four corners of the information, document or thing itself as having authored or previously received the information, document or thing; and - 4- 10946957 (iv) any expert or technical advisor retained or employed by any party for the purposes of this action, provided that said experts or consultants have executed a certification in accordance with Paragraph 6 below; and (v) other persons who may be specifically designated by consent of all attorneys of record or pursuant to an order of the Court, provided that said person has executed a certification in accordance with Paragraph 6 below. b. CONFIDENTIAL: Except as set forth herein or in any subsequent order of the Court or by express written consent of counsel of record, no documents, things or information designated as "CONFIDENTIAL" shall be, directly or indirectly, delivered, exhibited or disclosed to persons other than; (i) the Court; or any Court personnel, including any court reporter or typist recording or transcribing testimony in this action; and (ii) counsel for the parties in this proceeding and to other attorneys, paralegals, law clerks, and clerical staff working with those attorneys; (iii) any person identified from the four corners of the information, document or thing itself as having authored or previously received the information, document or thing; (iv) the parties to this action, provided, however, that disclosure may be made only to the extent necessary for the prosecution or defense of this litigation; (v) any actual or potential witness, provided that said witness has executed a certification in accordance with Paragraph 6 below; and (vi) any person testifying at a deposition, provided that said person has executed a certification in accordance with Paragraph 6 below; and - 5 - 10946957 (vii) any expert or technical advisor retained or employed by any party for the purposes of this action, provided that said experts or consultants have executed a certification in accordance with Paragraph 6 below; and (viii) other persons who may be specifically designated by consent of all attorneys of record or pursuant to an order of the Court, provided that said person has executed a certification in accordance with Paragraph 6 below. 6. Disclosure to Witnesses and Technical Advisers and Certification of Confidentiality, Before giving any witness, or technical adviser access to information, documents or things designated as "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" , the parties' Counsel who seeks to disclose such information to such witness, or technical adviser shall require the witness or technical adviser to read and agree to be bound by this Order by signing the following certification; I certify my understanding that documents, information, answers, and responses are provided to me pursuant to the terms and restrictions of the Court's Protective Order on Confidentiality in Hub Group, Inc., et at. v, Marcia Delaney ("Order"). I have been given a copy and have read that Order. I have had its meaning and effect explained to me by counsel who provided me with the information. I understand that such information and documents, and any copies, any notes or other memoranda regarding information in such documents, shall not be disclosed to others except in accordance with that Order, and shall be used only for purposes of this proceeding, - 6 - 10946957 The term "technical adviser" shall mean any person, including but not limited to a proposed expert witness or consultant, with whom counsel may deem it necessary to consult concerning technical, financial, or other aspects of this case for the preparation or trial thereof; provided, however, that no party, or person currently employed by a party, or person currently employed by any competitor shall so qualifY hereunder. 7. Safeguarding Confidential Information. The recipient of any "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" material provided pursuant to this Order shall maintain such information in a secure and safe area and shall exercise due and proper care with respect to its storage, custody and use, so long as it remains so designated. 8. Filing Procedures. Any party incorporating protected material into another document, including any document filed with the court, shall designate any affected portions of such a document as protected pursuant to this Protective Order. In the event "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" information is included with, or the contents thereof are in any way disclosed in any pleading, motion, deposition transcript, or other paper filed with this Court, such information shall be filed and kept under seal by the Clerk until further order of this Court by the following procedure; The document shall be submitted to the Court for filing in a sealed envelope or other appropriate sealed container on which shall be endorsed the title of this action, an indication of the nature of the contents of such sealed envelope or other container, the words "CONFIDENTIAL INFORMATION _ UNDER PROTECTIVE ORDER" and a statement substantially in the following form; This envelope contains information designated by one or more of the parties to this case as "confidential" and filed in this case by [name ofpartYJ in connection with its [motion for ...J and is not to -7 - 10946957 be opened nor the contents thereof to be displayed or revealed except by order of the Court. All material previously designated as such that is filed with or submitted to the Court shall be conspicuously marked "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" as set forth above in paragraph 4 prior to filing or submission. In the event that "CONFIDENTIAL - ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" material is used or disclosed in any hearing or at trial, that portion of the hearing or trial proceedings at which such material is disclosed shall be closed to the public and such material shall not lose its protected status by reason of such use or disclosure. If any person fails to file protected documents, things or information under seal, the party or non-party claiming confidentiality for the documents, things, or information, or any part thereof, may request that the Court place the filing under seal. 9. Final Disposition. Within ninety (90) days of the conclusion of this action, including any appeals, all "CONFIDENTIAL" or "CONFIDENTIAL _ ATTORNEYS' EYES ONL Y" information furnished pursuant to the terms of this Order, any notes reflecting Protected Information and all copies thereof, which are not in the custody of the Court, shall be returned to the party furnishing that Information or be destroyed (and certified by affidavit as having been destroyed) by the party in possession thereof, provided that counsel for the parties may retain their notes and any work product materials. 10. No Presumption of Protected Status. This Protective Order does not address discovery objections nor preclude any party from moving for any relief cognizable under the Pennsylvania Rules of Civil Procedure or this Court's inherent powers. In addition, the entry of this Order and the designation of any document or information as "CONFIDENTIAL _ - 8 - 10946957 ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" is not an admission or acknowledgment, and may not be used to argue, that such information or document actually constitutes confidential or trade secret information. 11. Challenging Confidential Designation. A party may oppose the designation of protected material at any time before trial by notifYing the opposing party in writing. If a party opposes the designation of any particular document designated as "CONFIDENTIAL _ ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" the parties shall attempt to resolve the dispute by agreement. If the parties are unable to resolve the dispute within five (5) business days after receiving written notice, then the party opposing the designation may file a motion with the Court to have the designation modified or removed. The burden remains on the designating party to demonstrate that the material in question contains "CONFIDENTIAL _ ATTORNEYS' EYES ONLY" or "CONFIDENTIAL" information as described in Paragraph 2 of this Order. Until a motion is filed and resolved by the Court, all documents and materials with which a confidential designation is being challenged shall be treated in the confidential manner that they have been designated by the producing party as prescribed in this Order. 12. Modification of Order. Nothing in this Order shall preclude any party from applying to the Court for an appropriate modification of this Order; provided, however, that before such an application, the parties involved shall make a good faith effort to resolve the matter by agreement. Furthermore, the parties can agree, without approval from the Court, on the exclusion of particular information, documents, answers, or responses from the scope of this Order. 13. Inadvertent Production. The inadvertent production pursuant to discovery by any party of any document or conununication that is protected by privilege, work product doctrine or - 9 - 10946957 statutory confidentiality will not operate as a waiver of the producing party's right to assert a defense to production of that document or communication, or any other document or communication, and any such material shall be returned promptly to the party producing it on timely written demand identif'ying the specific document(s). Any information, document or thing mistakenly produced or disclosed without a "CONFIDENTIAL" or "CONFIDENTIAL _ ATTORNEYS' EYES ONLY" designation may be subsequently designated by the producing party as "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY" at any time pursuant to the terms of this paragraph without waiving the confidential nature of the document or information. In each such case, the designating person shall provide to all other parties notice, either orally followed by written notice within five (5) business days or by written notice, of that subsequent designation and a copy of the document or thing marked in accordance with this paragraph. 14. Continuing Jurisdiction. Unless superseded by later order, this Order shall remain in full force and effect after the termination of this litigation and the Court shall retain jurisdiction over the parties, their attorneys, and all other persons to whom protected information has been disclosed for the purposes of enforcing the terms of this Order and/or redressing any violations thereof. 15. Non-Parties. The existence of this Order shall be disclosed to any non-party producing documents or information in this action who may reasonably be expected to desire confidential treatment of such information. Such non-parties may avail themselves of the protections of this Order. By availing themselves of the protections of this Order, such non- parties consent to the jurisdiction of this Court for purposes of enforcing the terms of this Order only. - 10 - i0946957 16. Exclusions. The restrictions set forth in any of the paragraphs hereof with respect to information, documents or things designated as "CONFIDENTIAL" or "CONFIDENTIAL _ ATTORNEYS' EYES ONLY" shall not apply to: a. any information, document or thing which at the time of disclosure to a receiving party is in the public domain; b. any information, document or thing which after disclosure to a receiving party becomes part of the public domain as a result of publication not involving a violation of this Order; or c. any information, document or thing which a receiving party can show was received by it, whether before or after the disclosure, from a source who obtained the information lawfully and under no obligation of confidentiality to the producing party. IT IS SO ORDERED this I). f"I day of Entered: ,2005. APPROVED AS TO FORM AND CONTENT. DATED: hg~ 2., 2005 DATED: August ]j, 2005 Seyfarth Shaw LLP By: D~ F. t.u..J.k 1.'1 n,w- Daniel F. Lanciloti I Attorneys for Plaintiffs Hub Group, Inc. and Hub City Terminals LLC ::'I/J!..2~ Michael R. Greco Attorneys for Defendant Marcia Delaney -11- 10946957 (\) ~ .,J 8Z:jJ 2/ ~ :;002 '3 ~T.:"'ll :.Ie; :j.=;,'-,~:~-./C-(~]:i.~