The opinion of the court was delivered by: Judge Thomas M. Rose
STIPULATED PROTECTIVE ORDER
Plaintiffs Sandra Weitzel and John Weitzel ("Plaintiffs") and Defendant Lear Corporation ("Defendant"), by and through their attorneys signing below, stipulate and agree as follows:
IT IS HEREBY ORDERED AS FOLLOWS:
1. On October 12, 2006, Plaintiffs, their attorneys, and their experts intend to perform a site inspection at Defendant's facility located at 2000 Schlater Road, Sidney, Ohio 45365 of the relevant areas and machines involved in Plaintiff Sandra Weitzel's injuries she sustained on December 1, 2004. During the site inspection, photographs and other electronic video (collectively hereinafter "Photographs") may be taken of these areas and machines that are of a confidential nature to Defendant including, without limitations: trade secrets and/or customer information and thus, properly the subject of a protective order.
2. "Photographs" include the originals and all copies.
3. Plaintiffs shall provide a copy of all Photographs obtained during the site inspection to Defendant.
4. The Photographs taken during the site inspection shall only be used by the parties solely for the prosecution or defense of this action.
5. The Photographs shall be held in confidence by Plaintiffs and their representatives; counsel for Plaintiffs and professional, clerical, secretarial or other support personnel of such counsel; persons not an attorney retained by Plaintiffs or counsel to assist in litigation such as accountants, economists and experts; court reporters retained in connection with depositions in this litigation; and witnesses at depositions; none of whom shall permit disclosure of the Photographs, except for purposes necessary to this litigation. The Photographs may also be disclosed to the Court as necessary, including but not limited to pleadings filed with the Court and at proceedings before the Court; in those events, however, the Photographs may be subject to seal by the Court, only if the party wanting a Photograph to be filed under seal provides sufficient legal justification to the Court for filing the Photograph under seal, and such Photograph is ordered sealed by the Court pursuant to Fed.R.Civ.P. 26(c).
6. If any Photograph is inadvertently disclosed to any person not authorized to have access thereto, Plaintiffs and/or their representatives shall notify in writing Defendant's legal representative in this matter with a copy of the notice sent to the Court. Such notice shall be sent three (3) days after the inadvertent disclosure is discovered, and shall identify by name, address, telephone number; and employer, each unauthorized person to whom disclosure was made, the date of such disclosure, and the surrounding circumstances.
7. Photographs marked as an exhibit in a deposition or other discovery document remain confidential, and may not be disclosed except in accordance with this order.
8. Photographs may be used at trial to the extent they are admissible. If Plaintiffs intend to use any Photograph at trial, counsel shall notify Defendant's counsel of that intention prior to trial.
9. At the conclusion of this action, including the exhaustion of all appeals, upon written request from the Defendant, Plaintiffs shall arrange for the destruction of the Photographs or the return of the Photographs ...