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Hackathorn v. Sunbeam Products, Inc.

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

August 31, 2017

RONALD HACKATHORN, PLAINTIFF,
v.
SUNBEAM PRODUCTS, INC., DEFENDANT.

          STIPULATED PROTECTIVE ORDER

          CHELSEY M. VASCURA, UNITED STATES MAGISTRATE JUDGE

         THE PARTIES TO THIS LAWSUIT, RONALD HACKATHORN, Plaintiff, by and through his attorneys and Defendant SUNBEAM PRODUCTS, INC., by and through its attorneys of record, do hereby stipulate to the entering of the following Protective Order.

         IT IS HERBY ORDERED that any and all documents produced or to be produced by any party to this action pursuant to any Request for Production of Documents or Request for Admission, served by any other party, or testimony by way of deposition, Interrogatory, or at trial for which the producing or testifying party asserts a claim of proprietary, confidential, trade secret or otherwise sensitive commercial information shall be subject to this Protective Order. The documents and testimony are referred to as “Protected Documents” and “Protected Testimony” as hereinafter defined and are to be maintained in a confidential manner under the procedures as hereinafter set forth:

         1. The term “Protected Document” as used herein shall mean any document produced during discovery or at the trial of this action which is of a trade secret, proprietary, confidential, or of a commercially sensitive nature and is designated at the time of production by the producing party to be a “Protected Document”. A “Protected Document” shall continue to be a “Protected Document” until such time as the producing party agrees in writing that the document is no longer considered to be a “Protected Document”. This paragraph includes references to “protected documents” in the remainder of this Order.

         2. The term “Protected Testimony” as used herein shall mean any testimony given by way of deposition, interrogatory or at trial of this action which is of a proprietary, confidential, trade secret, or of a commercially sensitive nature and is designated at the time the testimony is given and designed by the testifying party to be “Protected Testimony”. “Protected Testimony” shall continue to be “Protected Testimony” until such time as the testifying party agrees in writing that the testimony is no longer considered to be “Protected Testimony”. This paragraph includes references to “protected testimony” in the remainder of this Order.

         3. The documents designated and produced as “Protected Documents” and testimony designated as “Protected Testimony” shall be given confidential treatment as described below.

         4. Without further order of this Court, requesting or receiving parties may show “Protected Documents” and “Protected Testimony”, and may disclose the contents thereof, only to the following persons (hereinafter referred to as “Qualified Persons”):

a. Counsel of record in this action for requesting or receiving party;
b. Regular employees of such counsel assigned to and necessary to assist such counsel in the preparation of trial of this action;
c. Bona fide independent (i.e., not employed by or affiliated with a party or an affiliated company of a party) trial experts whom counsel, in good faith, reasonably anticipates will testify at trial as experts and only to the extent necessary for preparation or testifying by that expert, subject to all of the terms and conditions of this order;
d. Bona fide consultants whom counsel, in good faith, reasonably anticipate will not testify at trial as experts but are retained by counsel to aid in preparation for discovery and/or trial;
e. Provided that no disclosure shall be made to any person currently employed by any competitor of the party that are or have been in the business of designing, manufacturing or marketing electric bedding products producing the “Protected Document” or giving “Protected Testimony” except upon further order of this Court; provided further that, if such person to whom any “Protected Testimony” or “Protected Documents” have been produced becomes an employee of a competitor, such person shall immediately notify counsel for Plaintiff (who shall in turn immediately notify counsel for Defendant) and all such “Protected Documents” and “Protected Testimony” produced to such person shall be immediately returned to counsel for Plaintiff; and
f. The Court.

         5. Every “Protected Document” copied for production (including excerpts, digests, summaries or indices thereof) ...


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