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Rogers v. JPMorgan Chase Bank, N.A.

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

May 9, 2017

DANIEL ROGERS, Plaintiff,
v.
JPMORGAN CHASE BANK, N.A., et al., Defendants.

          Nelson M. Reid (0068434) Bricker & Eckler LLP Trial Attorney for Defendant.

          Marc E. Dann (0039425) The Dann Law Firm Co., LPA Trial Attorney for Plaintiff.

          STIPULATED PROTECTIVE ORDER

          Terence P. Kemp United States Magistrate Judge.

         Upon a 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:

         1. This 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.

         2. As 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.

         3. 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.

         4. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this action.

         5. 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 each party;
(d) expert witnesses and consultants retained in connection with this action, to the extent such disclosure is necessary for preparation, trial ...

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