United States District Court, S.D. Ohio, Eastern Division
SARAH A. WHEELER, Plaintiff,
CITY OF COLUMBUS, Defendant
M. SCHLEIN (0092194), JOHN S. MARSHALL (0015160), EDWARD R.
FORMAN (0076651), MARSHALL AND FORMAN LLC
JENNIFER L. SHEA (0085239) ASSISTANT CITY ATTORNEYS,
ATTORNEYS FOR DEFENDANTS
AGREED PROTECTIVE ORDER
CHELSEY M. VASCURA, MAGISTRATE JUDGE
parties, by and through their legal counsel, stipulate and
agree to the terms of this Order, under Fed.R.Civ.P. 26(c).
The parties further agree that the terms of this Agreed
Protective Order shall remain in place until further order of
the Court. The Court, having reviewed the agreement and
stipulation of the parties, finds that good cause supports
the entry of such an order and that justice so requires.
Accordingly, it is ORDERED:
documents produced in the course of discovery including
initial disclosures, all responses to discovery requests, all
deposition testimony and exhibits, other materials that 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
Form and Timing of Designation.
may designate documents as confidential and restricted in
disclosure under this Order by placing or affixing the words
“CONFIDENTIAL- SUBJECT TO PROTECTIVE ORDER” 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 - SUBJECT TO PROTECTIVE ORDER
designation. Documents shall be designated CONFIDENTIAL -
SUBJECT TO PROTECTIVE ORDER prior to or at the time of the
production or disclosure of the documents. The designation
“CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” 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.
Documents Which May be Designated CONFIDENTIAL -
SUBJECT TO PROTECTIVE ORDER.
party may designate documents as CONFIDENTIAL-SUBJECT TO
PROTECTIVE ORDER 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 medical or psychiatric information. Public
records and other information or documents that are publicly
available may not be designated as CONFIDENTIAL - SUBJECT TO
testimony shall be deemed CONFIDENTIAL - SUBJECT TO
PROTECTIVE ORDER 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 - SUBJECT TO
PROTECTIVE ORDER. Thereafter, the deposition transcripts and
any of those portions so designated shall be protected as
CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER, pending
objection, under the terms of this Order.
Protection of ...