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Grinston v. Medco Health Solutions, Inc.

United States District Court, Sixth Circuit

July 31, 2013

Alexandra Grinston, Plaintiff,
v.
Medco Health Solutions, Inc., et al., Agreed Protective Order Defendants.

AGREED PROTECTIVE ORDER

NORAH McCANN KING, Magistrate Judge.

WHEREAS, the parties in this litigation may produce in discovery documents, and information contained therein, that may contain trade secrets, or sensitive commercial, personnel, financial or proprietary business information; and

WHEREAS, the parties are interested in permitting discovery to proceed without delay occasioned by possible disputes regarding the confidential nature of certain information;

NOW, THEREFORE, upon good cause shown, and upon consent of the parties, it is hereby ORDERED THAT:

A. If a party in good faith believes that any written, recorded or graphic material, tangible items or any other form of information it produces in this action pursuant to pretrial discovery, court order, or agreement of the parties contains trade secrets or sensitive commercial, personnel, financial or proprietary business information, or employee personal information, it may designate such material as Confidential either by stamping the word "Confidential" on the document, by stamping "Confidential" on the cover page to such material, by any other means provided for in this Protective Order, or by other reasonable method as agreed to by the parties. (Material designated as required by this Protective Order is hereinafter referred to as "Confidential Material.") Materials designated as Confidential and all writings, including court papers, which quote from, summarize or comment upon any such materials shall be treated by the recipients as confidential as set forth hereinafter and used solely for the prosecution or defense of this action (including any appeals).

B. All depositions, including any document marked as an exhibit or otherwise appended to the deposition, if designated as "Confidential" by either party or a third party deponent within 72 hours after receipt of a deposition transcript, shall be treated as confidential under the terms of this Protective Order. During the 72-hour period, all transcripts and the information contained therein will be deemed to be confidential in their entirety under the terms of this Protective Order. Where practical, the party making such a designation will indicate the pages or sections of the transcript that are to be treated as confidential. The party taking the deposition shall retain the original transcript until such time as the filing of the transcript is required by the Court or desired by a party.

C. All interrogatory answers, or other responses to pretrial discovery requests, designated by either party as "Confidential" shall be delivered to the counsel for the party propounding said request without being filed with this Court unless said filing is subsequently ordered by this Court or desired by a party.

D. 1. No Confidential Material may be disclosed to any person except the following:

a. the parties, counsel of record for the parties, and counsel's employees;
b. outside experts and consultants working with counsel as counsel, in good faith, requires to provide assistance in the conduct of this action;
c. such officers, directors, partners, or employees of the parties as counsel, in good faith, requires to provide assistance in the conduct of this action;
d. the Court (including court reporters, stenographic reporters and other court personnel);
e. witnesses in the course of pretrial or trial proceedings; and
f. any other person as to whom the producing party agrees in writing (or as provided for ...

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