United States District Court, S.D. Ohio, Eastern Division
Matthew J.P. Coffman Coffman Legal, LLC Peter A. Contreras
Contreras Law, LLC Attorneys for Plaintiff
(Kathryn) Ellen Toth Ogletree, Deakins, Nash, Smoak &
Stewart, P.C. Attorney for Defendant
Honorable Algenon L. Marbley J.
STIPULATED PROTECTIVE ORDER
KIMBERLY A. JOLSON, MAGISTRATE JUDGE.
Parties to this Stipulated Protective Order, Plaintiff
Jennifer Davis (“Plaintiff”) and Defendant
Restoration Hardware, Inc. (“Defendant”)
(collectively, the “Parties”), have agreed to the
terms of this Order; accordingly, it is ORDERED:
documents produced in the course of discovery, including
initial disclosures, all responses to discovery requests, all
deposition testimony and exhibits, and all other materials
(hereinafter collectively “documents”) that
contain information that has been designated as
“CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER, ”
pursuant to Paragraph 4 of this Order (“Confidential
Information”), or information derived directly
therefrom, shall be subject to this Order. This Order shall
also apply to any photocopy, duplicate, computer file or
printout, compilation, synopsis, summary, quotation, digest
or notes (or any portion thereof) that includes Confidential
Information. This Order is subject to the Local Rules of this
Court and the Federal Rules of Civil Procedure on matters of
procedure and calculation of time periods.
Form of Designation.
may designate documents as confidential and restricted in
disclosure under this Order by placing or affixing the words
“CONFIDENTIAL” on the document in a manner that
will not interfere with the legibility of the document.
Timing of Designation.
shall be designated CONFIDENTIAL prior to, or at the time of,
the production or disclosure of the documents. Failure to
designate documents as CONFIDENTIAL at or before the time of
production shall not preclude the disclosing individual or
entity from thereafter, but no more than fifteen (15)
business days after production, in good faith making such a
designation and requesting the receiving party to so mark and
treat such documents or other media so designated from the
time of such designation forward. After such designation,
such documents or other media shall be fully subject to this
Order. No individual or entity shall incur liability for
disclosures made prior to notice of such designation.
Documents Which May be Designated CONFIDENTIAL.
party may designate documents as CONFIDENTIAL upon making a
good faith determination that the documents contain
information protected from disclosure by statute or that
should be protected from disclosure as confidential personal
information; medical or psychiatric information; trade
secrets; personnel records; financial information; or such
other sensitive commercial information that is not publicly
available. Public records and other information or documents
that are publicly available may not be designated as
portions of deposition testimony shall be considered
CONFIDENTIAL by a statement on the deposition record or by a
written statement furnished to the opposing counsel of record
and the official court reporter within ten (10) business days
of such testimony. Such designation shall be specific as to
the portions of the transcript or any exhibit to be
designated as CONFIDENTIAL. Thereafter, the deposition
transcripts and any of those portions so designated shall be
protected as CONFIDENTIAL, pending objection, under the terms
of this Order.
Use and Disclosure of ...