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Krempley v. Haugland Learning Center, LLC

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

February 15, 2018

TEMA KREMPLEY, Plaintiff,
v.
HAUGLAND LEARNING CENTER, LLC, Defendant.

          James S. Mowery, Mark C. Zronek, Attorneys for Plaintiff .

          Thomas J. Bonasera, Janay M. Stevens Attorneys for Defendant.

          Judge George C. Smith.

          STIPULATED PROTECTIVE ORDER

          Chelsey M. Vascura Magistrate Judge.

         I. INTRODUCTION

         The parties, by their undersigned counsel, stipulate to the following provisions of this Stipulated Protective Order, which is entered pursuant to Federal Rule of Civil Procedure 26(c).

         II. SCOPE OF STIPULATED PROTECTIVE ORDER

         In the course of discovery in this action, the parties may be required to produce information that constitutes, in whole or in part, protected information such as trade secrets, non-public research and development, commercial or financial information, or other information that may cause harm to the producing party or a non-party. This discovery may include information such as employee personnel files containing personal information about the parties and non-parties, protected medical and health information, financial information, and competitive commercial information. This information may be deemed confidential, as described below, and require certain protections to maintain the security and confidentiality of the information.

         III. DESIGNATION OF PROTECTED INFORMATION

         A. Scope: This Order governs the production and handling of any protected information in this action. Any party or non-party who produces protected information in this action may designate it as “Confidential” or “Attorneys' Eyes Only” consistent with the terms of this Order (collectively referred to as “Protected Information”). “Designating Party” means the party or non-party who so designates the protected information; “Receiving Party” means the party or non-party to whom such information was produced or disclosed. Whenever possible, the Designating Party must designate only those portions of a document, deposition, transcript, or other material that contains the protected information and refrain from designating entire documents. Nothing in this Order restricts a Designating Party's ability to use its own designated materials as it chooses. Such use shall not operate as a de facto waiver of the protections of this Order. In addition, any party may move to modify or seek other relief from any of the terms of this Order if it has first tried in writing and in good faith to resolve its needs or disputes with the other party(ies) pursuant to the terms of this Order and Local Rule 37.1.

         B. Application to Non-Parties: Before a non-party is given copies of Protected Information as permitted hereunder, it must first sign the acknowledgment to be bound to these terms and that is attached hereto as Exhibit A. If the non-party fails to do so, the parties to this action must resolve any such dispute before making disclosure of designated information as permitted hereunder to the non-party. If a non-party wishes to make designations hereunder, it must first sign the acknowledgment to be bound to these terms that is attached hereto as Exhibit A.

         C. Timing and Provisional Protection:

         Designations may be made at any time. To avoid potential waiver of protection hereunder, the Designating Party should designate information at the time of production or disclosure, including on the record during the taking of any testimony. Deposition testimony will be deemed provisionally protected for a period of 30 days after the transcript is released to the parties by the court reporter, although the parties may agree at any time to different timelines of provisional protection of information as Confidential or Attorneys' Eyes Only as part of one or more depositions. To retain any designations beyond the provisional period, a Designating Party must designate specific pages and lines of deposition testimony before the provisional period has expired. Such designations must be made in writing so that all counsel and court reporters may append the designation to all copies of the transcripts.

         D. Manner of Designation:

         Information may be designated hereunder in any reasonable manner or method that notifies the Receiving Party of the designation level and identifies with specificity the information to which the designation applies. If made verbally, the Designating Party must promptly confirm in writing the designation. Whenever possible, the Designating Party should stamp, affix, or embed a legend of “Confidential” or “Attorneys' Eyes Only” on each designated page of the document or electronic image.

         E. Definition of “Confidential” Information:

         “Confidential” information as used herein means information that the Designating Party reasonably and in good faith believes contains or reveals (1) trade secrets; (2) financial information, including the numeric quantifications of projected or actual sales, revenues, income, costs, expenses profits, earnings, or market shares; (3) information concerning competitors; (4) confidential and proprietary information about affiliates, parents, subsidiaries and third parties with whom the parties to this action have had business relationships; (5) personnel records, employment or other contracts, and salary or other compensation information; and (6) other information that any party reasonably and in good faith treats as confidential in the usual and ordinary course of its business, whether it is information contained in a document, information revealed during a deposition or other pretrial testimony, information revealed in an interrogatory answer or information otherwise revealed. Depending on the nature of information exchanged in discovery, examples of “Confidential” information may also include medical records and other medical information that would be protected by federal and state law. “Confidential” information shall expressly exclude any information that is public knowledge through no fault of the parties, their counsel, or any other parties identified in Paragraph V, infra, or is otherwise obtained through sources and means independent of and without reference to the “Confidential” information.

         F. Definition of “Attorneys' Eyes ...


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