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Bond v. Antero Resources Corp.

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

December 14, 2017

JEFFREY T. BOND, et al., Plaintiffs,
v.
ANTERO RESOURCES CORPORATION, et al., Defendants.

          Larry D. Shenise (0068461) Warner D. Mendenhall (0070165) Counsel for Plaintiffs.

          William G. Porter (0017296), Trial Attorney Peter A. Lusenhop (0069941) Steven A. Chang (0088321) Jessica Knopp Cunning (0089165) VORYS, SATER, SEYMOUR AND PEASE LLP Attorneys for Defendants Antero Resources Corporation.

          GEORGE C. SMITH JUDGE.

          STIPULATED PROTECTIVE ORDER

          KIMBERLY A. JOLSON UNITED STATES MAGISTRATE JUDGE.

         The parties to this Stipulated Protective Order have agreed to the terms of this Order and, accordingly, it is ORDERED:

         1. Scope.

         All documents produced in the course of discovery, including initial disclosures, all responses to discovery requests, all deposition testimony and exhibits, and other electronically stored information or materials which may be subject to restrictions on disclosure for good cause and information derived directly therefrom (hereinafter collectively “documents”), shall be subject to this Order concerning confidential information as set forth below. As there is a presumption in favor of open and public judicial proceedings in the federal courts, this Order shall be strictly construed in favor of public disclosure and open proceedings wherever possible. The Order is also subject to the Local Rules of this District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. Form and Timing of Designation.

         (a) Form. A party may designate a document as confidential and restricted in disclosure under this Order by placing or affixing the words “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS EYES ONLY” on the document in a manner that will not interfere with the legibility of the document and that will permit complete removal of the designation. Documents produced in native format may be designated as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY by separate letter indicating the Bates numbers and designations of each document so designated and/or by placing CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY in the title of the document. Deposition testimony may be designated CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY by making a statement so designating specific portions of testimony or exhibits on the record or in writing and directing the court reporter to mark the affected pages of the transcript.

         (b) Timing.

         (1) Initial Designation. Documents shall be initially designated CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY prior to or at the time of the production or disclosure of the documents. A statement designating testimony as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY shall be made at the deposition or hearing, or within thirty (30) days after receipt of a final transcript.

         (2) Subsequent Designation. A party may designate any document as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY subsequent to its first disclosure or production, provided that any such designation (i) must be in writing; (ii) must specifically identify the document designated; and (iii) shall only apply to the treatment and disclosure of such document after such written designation is received. Where a subsequent designation is made, any party that previously received the document shall immediately return copies of the document not bearing the “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS EYES ONLY” stamp and shall make all reasonable efforts to retrieve such document from any persons not authorized to hold it under this Order.

         3. Documents Which May be Designated CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS EYES ONLY.

         (a) CONFIDENTIAL. Any 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, competitively sensitive business or technical information, proprietary business methods or practices, and/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 CONFIDENTIAL.

         (b) CONFIDENTIAL-ATTORNEYS EYES ONLY. Any party may designate documents that meet the requirements of ¶ 3(a) as CONFIDENTIAL-ATTORNEYS EYES ONLY upon making a good faith determination that the disclosure of the documents to another party or non-party would create a heightened risk of harm to the competitive, commercial, financial, or business position of the disclosing party.

         4. Protection of Confidential Material.

         (a) General Protections. Documents designated CONFIDENTIAL shall not be used or disclosed by the parties, counsel for the parties, or any other persons identified in ¶ 4(b) for any purpose whatsoever other than to prepare for and to conduct discovery and trial in this action, including any appeal thereof.

         (b) Limited Third-Party Disclosures - CONFIDENTIAL Documents. The parties and counsel for the parties shall not disclose or permit the disclosure of any CONFIDENTIAL documents to any third persons except the following categories of persons:

(1) Parties. Named parties in this litigation, and their officers, directors, or employees assisting in the preparation and trial of this action or proceeding;
(2) Counsel. Counsel for the parties, and employees and agents of counsel who have responsibility for the preparation and trial of the action;
(3) Court. The Court, its officers, and court reporters providing stenographic or video services ...

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