United States District Court, S.D. Ohio, Eastern Division
M. Reid (0068434) Bricker & Eckler LLP Trial Attorney for
E. Dann (0039425) The Dann Law Firm Co., LPA Trial Attorney
STIPULATED PROTECTIVE ORDER
Terence P. Kemp United States Magistrate Judge.
showing of good cause in support of the entry of a protective
order to protect the discovery and dissemination of
confidential and proprietary information or information which
will improperly annoy, embarrass, oppress, or unduly burden
any party, witness, or person providing discovery or to whom
discovery pertains in this case, IT IS ORDERED:
Protective Order shall apply to all documents, materials, and
information, including without limitation, documents
produced, answers to interrogatories, responses to requests
for admission, deposition testimony, and other information
disclosed pursuant to the disclosure or discovery duties
created by the Federal Rules of Civil Procedure.
used in this Protective Order, the term
“document” is defined as provided in Fed.R.Civ.P.
34(a). A draft or non-identical copy is a separate document
within the meaning of this term.
Information designated “CONFIDENTIAL” shall be
information that is confidential, proprietary, personal
financial information, and/or implicates common law and
statutory privacy interests of the parties to this litigation
or any other person entitled to protection under Fed.R.Civ.P.
26(c), including, without limitation, personal financial
information, account information, private social security
numbers, and other private identifying information.
CONFIDENTIAL information also includes (1) any information
copied or extracted from information designated CONFIDENTIAL;
(2) all copies, excerpts, summaries, or compilations of
CONFIDENTIAL information; (3) any testimony, conversations,
or presentations by the parties or their counsel that might
reveal CONFIDENTIAL information.
CONFIDENTIAL information shall not be disclosed or used for
any purpose except the preparation and trial of this action.
CONFIDENTIAL documents, materials, and information
(collectively “CONFIDENTIAL information”) shall
not, without the consent of the party producing it or further
Order of the Court, be disclosed except that such information
may be disclosed to:
(a) attorneys actively working on this action;
(b) persons regularly employed or associated with the
attorneys actively working on this action whose assistance is
required by said attorneys in the preparation for trial, at
trial, or at other proceedings in this action;
(c) the parties, including designated representatives for
(d) expert witnesses and consultants retained in connection
with this action, to the extent such disclosure is necessary
for preparation, trial ...