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Eley v. Lanza

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

November 14, 2017

SCOTT ELEY, ET AL. Plaintiffs
v.
ANTOINTETTE LANZA, ET AL. Defendants

          WALTER H. RICE JUDGE

          STIPULATED PROTECTIVE ORDER

          Marty Beyer Beyer Law LLC, Attorney for Plaintiffs.

          Ellen M. Maniaci, Christine M. Haaker, Jessica E. Salisbury-Copper, THOMPSON HINE LLP Austin Landing 1 Attorneys for Defendant Antoinette Lanza

         This matter is before the Court upon the Joint Motion for Protective Order filed by Plaintiffs and Defendant Antoinette Lanza (collectively the "Parties'1 and individually, each a "Party"). To allow the parties to exchange discovery in this matter ("Action"), and pursuant to Federal Rule of Civil Procedure 26(c), the Parties have agreed to, and jointly ask the Court to enter, this Protective Order limiting the use and disclosure of confidential information. THEREFORE, in accordance with the Parties' joint motion, and for good cause shown, this Court enters the following Stipulated Protective Order ("Order"):

         l. "Discovery Material" means all documents, electronic data, testimony, or other information produced, subpoenaed, transcribed, given to, served upon, or filed by any Party or non-party ("Designating Party") in connection with formal or informal discovery, hearing, subpoena, or trial proceeding (whether in the form of depositions, transcripts, interrogatory answers, document productions, responses to requests for admission, or otherwise), or in any pleading, motion, affidavit, declaration, brief, or other document submitted to the Court.

         2. ''Confidential Information" means Discovery Material containing financial. business or other sensitive information, marked as "CONFIDENTIAL" in accordance with Paragraph 8, that a Designating Party believes in good faith is, or contains, proprietary, confidential, commercially sensitive, or trade secret information and is entitled to confidential treatment pursuant to Federal Rule of Civil Procedure 26(c), or any other statute or regulation restricting disclosure. Confidential Information shall also include any copy, excerpt, digest, compilation, or summary relying in any part on, or including in whole or in part, Confidential Information.

         3. Confidential Information shall not be used by a Party or any non-party receiving such Confidential Information ("Receiving Party"), including those persons set forth below, for any purpose other than this Action. Confidential Information shall not be disclosed by the Receiving Party without the prior written consent of the Designating Party or an order of this Court, except to the following:

a. Counsel for the Parties and Counsels' employees;
b. The Parties;
c. Litigation consultants, contractors, and persons designated as expert witnesses in this Action;
d. The Court and its employees, including, without limitation, court reporters, employees in the Clerk's Office, and staff attorneys, provided that the Confidential Information is filed in accordance with the terms of this Order; and
e. Witnesses or potential witnesses that are not Parties, but only to the extent that there is a good faith belief that the witness or potential witness has prior personal knowledge of the Confidential Information.

         4. Regarding the Receiving Parties designated in Paragraph 3(c) and (e) of this Order, no disclosure of Confidential Information will be made until the Receiving Party has been provided with a copy of this Order and has agreed to be bound by signing the Declaration of Compliance attached to this Order as Exhibit A (''Declaration").

         5. A witness who: (1) furnishes Confidential Information; or (2) is a person that authored, was an addressee, or received a copy of the Confidential Information may, during the trial or deposition testimony, review Confidential Information that may be relevant to the witness's testimony without signing the Declaration, provided the person is instructed in writing or on the record that they are bound by this Order and, at the end of the deposition or trial, the document(s) containing ...


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