United States District Court, S.D. Ohio, Eastern Division
Patrick Kasson (0055570) Reminger Co., LPA Counsel for Ohio
Gastroenterology Group, Inc.
Sabo (0089226) The Friedmann Firm, LLC Counsel for Plaintiff
A. SARGUS, JR. judge.
STIPULATED PROTECTIVE ORDER
KIMBERLY A. JOLSON UNITED STATES MAGISTRATE JUDGE
come the parties, pursuant to Fed. Rule 26(c), and hereby
stipulate and agree as follows:
party may designate as “Confidential” any
information, testimony, and documents which that party
believes to contain special formulas, financial data,
business and marketing plans, competitive analyses, or any
other confidential information of a non-public nature
regarding Plaintiff or any Defendant (collectively referred
to herein as “Protected Information”). However,
this Order shall not apply to any documents which have been
filed with any governmental agency and are now available to
the general public or are in the public domain.
Protected Information is produced by a non-party as a result
of a subpoena or other document request, any party to this
litigation may serve notice on the other party that it
considers such documents to be covered by the terms of this
Stipulated Protective Order. Upon receiving such notice, all
parties will mark the documents as “Confidential”
and treat them as Protected Information under the terms of
this Stipulated Protective Order.
used herein, the term “Disclosing Party” refers
to the party disclosing Protected Information in discovery or
proceedings in this matter. “Receiving Party”
refers to the party to whom such Protected Information is
disclosed in discovery or proceedings in this matter.
the Receiving Party objects to the designation of information
or material as “Confidential, ” that party shall
object in the first instance by letter to counsel for the
Disclosing Party. If the dispute is not resolved by
agreement, then the dispute shall be resolved by the Court.
Until such agreement is reached, or Order is entered, the
parties must abide by the “Confidential”
Except with prior written consent of the Disclosing Party or
upon Order of this Court, Protected Information may be
inspected by and disclosed only to the following persons and
only for the purposes of conducting this litigation:
a) The parties;
b) Attorneys of record in this action (including the staff of
c) The Court and, if deemed necessary by the Court, Court