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Merendo v. Ohio Gastroenterology Group, Inc.

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

November 22, 2017

Benita Merendo, Plaintiff,
v.
Ohio Gastroenterology Group, Inc., Defendant.

          Patrick Kasson (0055570) Reminger Co., LPA Counsel for Ohio Gastroenterology Group, Inc.

          Rachel Sabo (0089226) The Friedmann Firm, LLC Counsel for Plaintiff Merendo

          EDMUND A. SARGUS, JR. judge.

          STIPULATED PROTECTIVE ORDER

          KIMBERLY A. JOLSON UNITED STATES MAGISTRATE JUDGE

         Now come the parties, pursuant to Fed. Rule 26(c), and hereby stipulate and agree as follows:

         1. Any 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.

         2. When 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.

         3. As 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.

         4. If 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” designation.

         5. 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 such attorneys);
c) The Court and, if deemed necessary by the Court, Court ...

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