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Norris v. Glassdoor, Inc.

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

January 2, 2018

STACY NORRIS, Plaintiff,
v.
GLASSDOOR, INC., Defendant.

          WE SO STIPULATE and agree to abide by the terms of this Order Rayl L. Stepter, Attorney for Plaintiff Stacy Norris

          WE SO STIPULATE and agree to abide by the terms of this Order Joseph N. Gross, Richard E. Hepp Attorneys for Defendant Glassdoor, Inc. Benesch, Friedlander, Coplan & Aronoff LLP

          ALGENON L. MARBLEY, 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; 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, other 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. The Order is subject to the Local Rules of this Court and the Federal Rules of Civil Procedure on matters of procedure.

         2. Form and Timing of Designation.

         A party or third-party producing documents or information may designate documents 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 CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY designation. Documents shall be designated CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY prior to or at the time of the production or disclosure of the documents. A party or third-party producing documents may remedy an inadvertent failure to identify documents as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY by supplemental written notice within a reasonable time after production by submitting to the receiving party properly marked documents or copies thereof, for which there was an inadvertent failure to identify the documents as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY. The designation “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS' EYES ONLY” does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order. A party which, prior to this Court's entry of this Order, has previously produced documents in the course of discovery which would properly be designated as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY pursuant to the terms of this Order shall be permitted a period of ten (10) calendar days from entry of this Order to re-designate any documents previously produced. In such circumstances, the designating party shall provide written notice to the other party of such documentation, and shall provide new copies of the documents to be designated in accordance with the terms of this Order.

         3. Documents Which May Be Designated CONFIDENTIAL.

         Any party or third-party producing documents may designate them 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, 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.

         4. Documents Which May Be Designated CONFIDENTIAL-ATTORNEYS' EYES ONLY.

         A party may designate as “CONFIDENTIAL-ATTORNEYS' EYES ONLY” and subject to this Protective Order any material in this action that the designating party reasonably believes contains, reflects, or otherwise discloses trade secrets, confidential research and development, or other confidential or proprietary commercial information not otherwise available to the public, including but not limited to: (a) highly sensitive information relating to the use of proprietary strategies and methodologies, including the development of new proprietary strategies and methodologies; (b) highly sensitive non-public financial information concerning a party, including but not limited to sales goal information; (c) highly sensitive business planning or strategy information; (d) highly sensitive sales or marketing information; (e) customer lists or agreements, negotiations, or correspondence regarding customer agreements, royalties, royalty rates, royalty reports, pricing, revenue, profit and loss information or any similar confidential customer information; or (f) following the finding of a waiver of the attorney-client privilege, communications either between attorneys for an entity or between an entity and its attorney.

         5. Redacted Copies.

         A party producing documents labeled as CONFIDENTIAL- ATTORNEYS' EYES ONLY shall also provide a second version of the same documents with all highly sensitive information redacted, so that such second version may be designated as CONFIDENTIAL pursuant to the terms of this Order.

         6. Depositions.

         Deposition testimony shall be deemed CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY if designated as such. Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY. Thereafter, the deposition transcripts and any of those portions so designated shall be protected as CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY, pending objection, under the terms of this Order.

         7. Protection of Confidential and Confidential-Attorneys' Eyes Only Material.

         (a) General Protections.

         Documents designated CONFIDENTIAL or CONFIDENTIAL-ATTORNEYS' EYES ONLY under this Order shall not be used or disclosed by the parties, counsel for the parties or any other persons identified in ¶¶ 7(b) and 7(c) 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 of Confidential Documents.

         The parties and counsel for the parties shall not disclose or permit the disclosure of any CONFIDENTIAL documents to any person or entity except as set forth in subparagraphs (i) - (v) below. Subject to these requirements, the following categories of persons may be allowed to review documents that have been designated CONFIDENTIAL:

(i) Counsel.
Counsel for the parties and employees and those agents of counsel who have responsibility for the preparation and trial of the action, including, but not limited to, any in-house counsel ...

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