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Elliott v. First Federal Community Bank of Bucyrus

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

May 8, 2017

G. Ralph Elliott, Plaintiff,
v.
First Federal Community Bank of Bucyrus, Defendant.

          NEWHOUSE, PROPHATER, KOLMAN & HOGAN, LLC Michael S. Kolman, D. Wesley Newhouse Counsel for Defendants

          Aaron E. Michel Attorney for Plaintiff

          Algenon L. Marbley, Judge

          Elizabeth Preston Deavers, Magistrate Judge

          AGREED PROTECTIVE ORDER

          NORAH MCCANN KING UNITED STATES MAGISTRATE JUDGE

         By agreement of counsel for Plaintiff and Defendant (collectively, "the Parties"), pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, IT IS HEREBY ORDERED as follows:

         1. This Agreed Protective Order governs the use of information and documents produced through discovery in the above captioned case, and is also effective for documents and information produced by the parties before the date of this Order. In the event that a party determines that a document produced prior to the entry of this Order should have been designated Confidential as defined by this Order, and to apply such a designation to such a document, that party shall identify and describe each such document, and describe the basis for such a designation. Such post-production designation shall apply only after the date it is made.

         2. The terms defined in this paragraph shall have the meaning provided and shall apply throughout this Agreed Protective Order. Defined terms may be used in the singular or plural.

a. "Producing Party" means the Party or person who produces or who is asked to produce documents or information that the Party or person considers to be "Confidential."
b. "Receiving Party" means the Party receiving or requesting production of documents or information designated as "Confidential."
c. "Confidential Documents and Information" means all information whether or not embodied in a document or other physical medium which the Producing Party believes in good faith is confidential, private or personal information, and is designated as "confidential" by the producing party. Confidential Documents and Information shall be made subject to the provisions of this Agreed Protective Order. Confidential Documents and Information shall include, but is not limited to, documents containing financial information. Confidential Documents and Information also includes any data, summary, notes, abstract, compilation, or information obtained, derived or generated from Confidential Documents or Information.
d. "This Litigation" means the lawsuit captioned above, including all related pre-filing negotiations among the Parties, discovery proceedings, hearings, administrative actions, and pre-trial, trial and post-trial activities related thereto.
e. "Litigation Documents" means all pleadings, motions, affidavits and related papers; answers to interrogatories and requests for admissions; all documents produced or exchanged in the course of discovery, settlement negotiations, trial preparation or trial; and all transcripts of testimony given in deposition, in hearings or at trial in connection with this Litigation.

         3. The Parties agree that they shall use Confidential Documents and Information only for the purposes of this Litigation, not for any personal, business, competitive, commercial, governmental, or publicity ...


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