Stephanie S. Hathaway (#0074262), REMINGER CO., L.P.A., Cleveland, Ohio, Attorney for Defendant.
STIPULATED PROTECTIVE ORDER
ELIZABETH PRESTON DEAVERS, District Judge.
The parties have requested a protective order relating to certain alleged confidential information in the above-captioned matter. It is stipulated and agreed by counsel for the parties in this action that the following protective conditions shall apply to and govern the handling of documents, testimony, deposition exhibits, interrogatory responses, admissions, and any other information or material that is produced, given or exchanged by and among the parties and any non-parties to this action in connection with this litigation.
1. The following definitions shall apply to this Stipulation and Protective Order:
a. "Confidential material" shall mean any produced material designated as confidential pursuant to Paragraph 2 hereof.
b. "Attorneys' Eyes Only" shall mean any produced material designated as "Attorneys' Eyes "Only" pursuant to Paragraph 2 hereof.
c. "Disclose" shall mean to reveal, provide, describe or make known to any person produced material or any information contained therein.
d. "Party" shall mean a party to this action, an affiliated entity, and any employee of such party or affiliated party.
e. "Produced material" shall mean any testimony, document, information, interrogatory answer, or thing obtained by any party or counsel for any party through discovery in this litigation, including testimony, documents and information obtained from nonparty witnesses.
f. "Receiving party" shall mean any party, including the party's counsel, to whom produced material is furnished.
2. Any party may designate as "Confidential" or "Attorneys' Eyes Only" any material produced by it which the designating party deems in good faith to contain confidential information pertaining to that party or any other entity or person, including but not limited to information that is: private, sensitive, medical, personal financial information, proprietary, trade secrets, or other highly confidential information. This designation of documents may be made by typing, writing or stamping the first page of the document "Confidential" or "Attorneys' Eyes Only" or by informing counsel for the receiving party in writing that the documents are "Confidential" or "Attorney Eyes' Only." Interrogatory answers designated "Confidential" or "Attorneys' Eyes' Only" shall be set forth separately, and the first page shall be marked "Confidential" or "Attorney Eyes' Only" Deposition testimony or portions of the testimony may be designated "Confidential" or "Attorneys' Eyes Only" on the record of the deposition or by letter to all counsel mailed within five (5) days after receipt of the deposition transcript by designating counsel.
3. "Confidential" and "Attorneys' Eyes Only" material shall be used only for the purposes of this case, appeals, related cases, affiliated cases and/or collection actions, including trial and preparation for trial; and shall not be disclosed to any person or governmental agency or otherwise made public except in compliance with the terms of this Stipulation and Protective Order or by order of Court or as required by law.
a. Except as otherwise provided, "Confidential" material may be disclosed by the ...