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Jack v. South Park Ventures, LLC

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

January 4, 2018

JOHN JACK, Plaintiffs,




         This Stipulated Protective Order (the “Order”) is entered into with respect to the above-captioned matter (the “Action”) between and among Plaintiffs, John Jack and Tri-State Disposal, LLC (“Plaintiff”), and Defendants, Dean Grose and South Park Ventures, LLC (“Defendants”). Plaintiff and Defendants are referred to collectively as “the Parties.”

WHEREAS, during the course of discovery in this matter, it may be necessary for a person or entity (“Producing Person”) to disclose documents or information to a Party to this Action (“Receiving Party”), including in response to deposition notices, subpoenas or other means of discovery (“Discovery Requests”).

         WHEREAS, to expedite the exchange of discovery materials, to facilitate the prompt resolution of disputes over confidentiality, and to protect discovery material entitled to be kept confidential, the Parties stipulate and agree as follows:

         1. This Order applies to all Parties to this Action and also to non-parties that are served with subpoenas in connection with the Action or who otherwise produce documents or are noticed for deposition in connection with the Action, and all such non-parties are entitled to the protection afforded hereby upon signing the Acknowledgment to be Bound in the form attached and agreeing to be bound by its terms. This Order applies to all information, documents and things exchanged in or subject to discovery in this Action (collectively referred to as “Discovery Material”).

         2. A Producing Person may designate Discovery Material as “Confidential” if such Producing Person believes in good faith that such Discovery Material constitutes or includes information: (i) that has not been made public and that the Producing Person would not want to be made public in the ordinary course of its activities, including but not limited to technical, business, financial, third-party, personal or other information of a nature that can be protected under the Ohio Rules of Civil Procedure; or (ii) that the Producing Person is under a preexisting obligation or nondisclosure agreement to a third-party to treat as confidential; or (iii) that the Producing Person has in good faith been requested by another party or non-party to so designate on the ground that such other party or non-party considers such material to contain information that is confidential or proprietary to such party or non-party.

         3. Where reasonably practicable, Confidential material shall be designated by the Producing Person as such by marking every such page “Confidential.” Such markings should not obliterate or obscure the content of the material that is produced. Where marking every page of such materials is not reasonably practicable, such as with certain native file documents, a Producing Person may designate material as Confidential by informing the person to whom the material is provided in writing in a clear and conspicuous manner at the time of production of such material, that such material is Confidential.

         4. Confidential material shall be given, shown, made available to or communicated only to the following:

a. Plaintiff;
b. Defendants;
c. counsel of record who have entered an appearance on behalf of a party and employees of such counsel who are assisting in the preparation of this action;
d. the Court, its officers and clerical staff;
e. outside photocopying, graphic production services, or litigation support services; f. expert witnesses employed by a Party for this Action;
g. court reporters, stenographers, or video graphers who record deposition or other testimony in the litigation; and
h. any other person or entity to whom the Producing Person may consent in writing.

         5. Before any person or their representative identified in Paragraph 4(e), (f), (g) or (h) is given access to Discovery Materials designated “Confidential” if allowed by the above rules, such person or their representative shall be provided with a copy of this Order and shall acknowledge in a written statement that he or she read the Order and agrees to be bound by the terms thereof. Such written statements shall be retained in the files of counsel for the party who gave access to the Discovery Materials designated as Confidential to the ...

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