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Wysong v. Nagengast

United States District Court, S.D. Ohio, Western Division, Dayton

March 14, 2017

PAUL WYSONG, et al., Plaintiffs,
v.
JUDY NAGENGAST, et al, Defendants.

          Jeffrey T. Cox Attorneys for Defendants Judy Nagengast and Continental Design Co., Inc.

          Jason P. Matthews Attorneys for Plaintiffs Paul Wysong and Chelsea Wysong

          Sharon Ovington Magistrate Judge

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

          Walter H. Rice Judge

         WHEREAS, Plaintiffs Paul and Chelsea Wysong ("Plaintiffs") and Defendants Judy Nagengast and Continental Design Co., Inc. ("Defendants") (individually, the "Party, " and collectively, the "Parties") recognize that, pursuant to discovery or otherwise during the course of the lawsuit between Plaintiffs and Defendants ("this Action"), the Parties may be required to disclose financial information, trade secrets information or other confidential and proprietary information within the meaning of Fed.R.Civ.P. 26(c);

         WHEREAS the Parties, through Counsel, have stipulated to this Stipulated Protective Order and Confidentiality Agreement ("Protective Order") pursuant to Fed.R.Civ.P. 26(c) to prevent disclosure of such confidential and proprietary information; and

         WHEREAS the Parties agree that this Protective Order shall be effective and binding throughout all proceedings relating to this Action, and shall apply to all discovery in this Action, including discovery of non-parties, who shall be entitled to designate documents or testimony in accordance with this Protective Order.

         IT IS ORDERED AS FOLLOWS:

         1. All information that has been provided by the Parties in the course of this Action or will be produced by the Parties in the course of this Action shall be used solely for the purpose of preparation and trial of this Action and for no other purpose whatsoever, and shall not be disclosed to any person except in accordance with the terms of this Protective Order.

         2. A Party or Parties who are producing, using or disclosing ("Producing Party") information or documents (as defined by Fed.R.Civ.P. 34(a)) or any summaries or compilations derived there from, including but not limited to productions of documents, answers to interrogatories, responses to requests for admissions, deposition testimony, exhibits, and all other discovery, regardless of format ("Discovery Material") may designate the Discovery Material produced, used or disclosed in connection with this Action as "CONFIDENTIAL, " subject to the protections and requirements of this Protective Order, if so designated in writing to the other Parties by affixing, or causing to be affixed, such designation to any document or piece of information, or orally if recorded as part of a deposition, pursuant to the terms of this Protective Order.

         3. Any Discovery Material designated as "CONFIDENTIAL" shall be maintained as confidential, not to be disclosed, and shall be used by the Party or Parties receiving such Discovery Material ("Receiving Party") solely in connection with this Action and shall not be disclosed to anyone other than:

A. The Court, including court personnel, any court exercising appellate jurisdiction over this Action, and stenographers transcribing a deposition;
B. The Receiving Party, and employees for a Receiving Party to whom it is necessary that the material be shown for purposes of this Action and who have signed a Declaration in the form of Exhibit A attached;
C. Outside counsel of record who are signatories to this Protective Order for a Receiving Party and employees of such attorneys and law firms to whom it is necessary that the material be shown for purposes of this Action;
D. Independent experts, consultants, investigators, or advisors of a Receiving Party, who are qualified by knowledge, skill, experience, training or education and retained by outside counsel to assist in the preparation or trial of this Action and to whom it is necessary that the information be disclosed, and who have signed a Declaration in the form of Exhibit A attached;
E. Document contractors, electronic discovery contractors, exhibit contractors, graphic art contractors and jury consultants who are engaged to assist in the preparation or trial of this Action and to whom it is necessary that the material be shown for purposes of this Action, and who have signed a Declaration in the form of Exhibit A attached; and
F. Potential witnesses to the extent the Discovery Material was authored by or addressed to the person or such person is established as knowledgeable of such information or contents of the Discovery Material prior to disclosing the Discovery Material.

         4. In the case of a document or thing, a designation of "CONFIDENTIAL" shall be accomplished by marking every page of the document or conspicuously marking the thing with the appropriate legend "CONFIDENTIAL" in a manner that shall not interfere with the legibility of the information contained in the Discovery Material.

         5. As set forth in this paragraph and its subparts, information conveyed or discussed in testimony at a deposition shall be subject to this Protective Order, provided that it is designated as "CONFIDENTIAL" orally or in writing either at the time of the deposition or after receipt by ...


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