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Tchankpa v. Ascena Retail Group

United States District Court, S.D. Ohio, Eastern Division

April 10, 2017

KASSI TCHANKPA, Plaintiff,
v.
ASCENA RETAIL GROUP Defendant.

          William J. O'Malley 4591 Indianola Ave. Attorney for Plaintiff Kassi Tchankpa

          Brooke E. Niedecken (0079142) Julia R. Baxter (0086648) LITTLER MENDELSON, P.C. Attorneys for Defendant Ascena Retail Group

          Chief Judge Edmund A. Sargus, Jr.

          AGREED PROTECTIVE ORDER

          Trence P. Kmp United States Magistrate Judge

         Plaintiff Kassi Tchankpa (“Tchankpa”) and Defendant Ascena Retail Group[1] (“Ascena”), through their attorneys, having stipulated and agreed to the entry of a Protective Order, and the Court finding that good cause supports entry of this Protective Order and that justice so requires it, IT IS HEREBY ORDERED, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, that the documents and other information, including the substance and content thereof, produced or otherwise disclosed by any party or non-party in discovery in this litigation, shall be subject to the terms and provisions of this Protective Order as follows:

         1. Ascena, Tchankpa, and/or any other related non-parties involved in any way in this litigation are required to maintain the confidentiality of the following documents and information obtained through discovery in this litigation or obtained and marked as exhibits in depositions in this case (hereinafter referred to as “confidential material”): (a) documents and information from personnel files of current and former employees of Ascena; (b) documents and information pertaining to disciplinary actions by or against current or former employees of Ascena; (c) lists of names of employees currently or formerly employed by Ascena; (d) medical, family medical, and personal financial and tax information of any person; (e) any document that contains or relates to sensitive financial, business, or personal information, including but not limited to, trends and projections, business strategies and associated information, and any Ascena customer information; and (f) any document or information that a party in good faith believes to contain confidential or proprietary business information, which is designated by the party as “CONFIDENTIAL.” Such designation shall subject the information produced or provided under said designation to the provisions of this Protective Order.

         2. Ascena and/or Tchankpa may designate deposition testimony or any portion of deposition testimony as “CONFIDENTIAL” by advising the court reporter and counsel of such designation during the course of the deposition or at any time thereafter. Portions of any deposition designated “CONFIDENTIAL” are to be either: (a) redacted before the deposition transcript is filed with the Court; or (b) filed with the Court under seal, bearing substantially the following designation: “Portions of this deposition were taken subject to a Protective Order. These portions shall remain sealed until further agreement of the parties.”

         3. Whenever a party wishes to file any confidential material with the Court, the party may either: (a) redact all of the information contained on any page that is marked “CONFIDENTIAL” before filing said document with the Court; (b) if the party wishing to file the confidential material is the party asserting confidential treatment (hereafter “designating party”), that party may, at their discretion, redact only that information that it deems confidential before filing with the Court; or (c) separately file the document under seal with Court. If a party wishes to file a document that has been marked confidential with the Court, the party will file a motion establishing good cause for the document to be preserved under seal. A document may not be filed under seal without prior approval of the Court.

         4. Ascena or Tchankpa may designate as “CONFIDENTIAL” specific responses to information requests by labeling the specific response “CONFIDENTIAL.”

         5. Except upon prior written consent of the designating party or upon further order of a court of competent jurisdiction, confidential material shall be held in strict confidence and shall be used solely for the purposes of prosecution or defense of this litigation. Access to confidential material shall be limited to:

(a) Counsel for the respective parties, including in-house counsel (and employees of said counsel who are assisting in the prosecution or defense of this litigation);
(b) Experts and consultants (including independent experts and consultants, and employees or clerical assistants of said experts) who are employed, retained or otherwise consulted by counsel or a party for the purpose of analyzing data, conducting studies or providing opinions to assist in such litigation; and
(c) Parties or officers or employees of the respective parties who have a reasonable business need to review such documents, testimony, information or material.

6. Confidential material shall not be disclosed to any expert or consultant (as defined in paragraph 5(b)) unless and until such person has signed and returned to all counsel a written agreement that he/she agrees ...


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