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Majestic Building Maintenance, Inc. v. Huntington Bancshares Inc.

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

August 31, 2017

MAJESTIC BUILDING MAINTENANCE, INC. Plaintiff,
v.
HUNTINGTON BANCSHARES INCORPORATED dba THE HUNTINGTON NATIONAL BANK Defendant.

          Brett A. Wall, Trial Attorney Lisa M. Ghannoum Baker & Hostetler LLP Attorneys for The Huntington National Bank

          Sean M. Kohl, Andrew J. Gerling, Troy J. Doucet, Attorneys for Majestic Building Maintenance, Inc.

          JUDGE, JAMES L. GRAHAM

          STIPULATED PROTECTIVE ORDER

          KIMBERLY A. JOLSON, UNITED STATES MAGISTRATE JUDGE

         Majestic Building Maintenance, Inc. and The Huntington National Bank (each individually a “Party, ” and collectively the “Parties”) acknowledge that discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. The Parties agree that good cause exists to protect the confidential, proprietary, or private nature of the information contained in documents, interrogatory responses, responses to requests for admission, and deposition testimony. Accordingly, the Parties agree that the entry of this Stipulated Protective Order (“Protective Order”) is warranted to protect against disclosure of such information.

         Based upon the above stipulation of the Parties, and the Court being duly advised, IT IS HEREBY ORDERED as follows:

         1. “Confidential Material” shall include the following documents and tangible things produced or otherwise exchanged among the Parties and/or third parties subpoenaed by a party to the litigation, including but not limited to electronically stored information: (a) trade secret or other confidential research, development, proprietary or commercial information that is suitable for protection under Federal Rule of Civil Procedure 26(c)(1)(G); (b) “personally identifiable information” defined herein as an individual's name, address, or phone number in the combination with one or more of the following: date of birth, social security number, driver's license number or other state identification number or a foreign government equivalent, passport number, financial account number, payment card number, insurance claim numbers or insurance policy numbers; and (c) any other information that may be protected from disclosure under an individual's constitutional right of privacy such as employment information.

         The Parties may identify additional documents during the course of the litigation, and may agree that these documents should also be designated Confidential Material.

         2. The protections conferred by this Protective Order cover not only Confidential Material as defined above, but also (1) any information copied or extracted from Confidential Material; (2) all copies, excerpts, summaries, or compilations of Confidential Material; and (3) any testimony, conversations, or presentations by the Parties or their counsel that might reveal Confidential Material. However, the protections conferred by this Protective Order do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         3. A receiving party may use Confidential Material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential Material may be disclosed only to the categories of persons and under the conditions described in this Protective Order. Confidential Material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Protective Order.

         4. Unless otherwise ordered by the Court or permitted in writing by the designating party, a receiving party may disclose any Confidential Material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel of record in this action to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation;
(c) experts and consultants engaged for purposes of the litigation to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment ...

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