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Hebert v. Chesapeake Operating, Inc.

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

February 23, 2018

JOSEPH HEBERT, individually and on behalf of all others similarly situated, Plaintiffs,
v.
CHESAPEAKE OPERATING, INC. AND CHESAPEAKE OPERATING, LLC, Defendants.

          Michael A. Josephson Josephson Dunlap Law Firm Richard M. Schreiber Josephson Dunlap Law Firm Robert E. DeRose, II Barkan Meizlish Handelman Goodin DeRose Wentz, LLP ATTORNEYS FOR PLAINTIFFS JOSEPH HEBERT, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED

          David B. Jordan (Attorney-in-Charge) Allison C. Williams LITTLER MENDELSON, P.C. Alex R. Frondorf LITTLER MENDELSON, P.C. ATTORNEYS FOR DEFENDANTS CHESAPEAKE OPERATING, INC. AND CHESAPEAKE OPERATING, LLC

          STIPULATED PROTECTIVE ORDER

          KIMBERLY A. JOLSON UNITED STATES MAGISTRATE JUDGE.

         WHEREAS, the parties in the above-captioned matter agreed that the proceedings in the above-captioned matter may involve the discovery and use of confidential, non-public, sensitive, and/or proprietary business, employment, tax, financial, and personally identifiable information, documents and other materials;

         WHEREAS, the parties agreed to produce such documents only on the agreement that such “Confidential Information” will be disclosed only as provided herein;

         WHEREAS, the parties agreed to stipulate to protect certain protected documents, data (including electronically stored information) and other information, including without limitation, metadata (collectively “Documents”), against claims of waiver and inadvertent production in the event they are produced during the course of this litigation whether pursuant to a Court Order, a parties' discovery request or informal production;

         WHEREAS, the parties wish to comply with discovery deadlines and complete discovery as expeditiously as possible, while preserving and without waiving any evidentiary protections or privileges applicable to the information contained in the Documents produced, including as against third parties and other Federal and State proceedings;

         WHEREAS, the parties agreed that disclosure and discovery activity in this litigation are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted;

         WHEREAS, the parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to information or items that are entitled under the applicable legal principles to treatment as confidential;

         THEREFORE, the parties seek the entry of an Order, pursuant to Federal Rule of Civil Procedure 26(c), governing the disclosure of documents and information therein pertaining to “Confidential Information” on the terms set forth herein.

         IT IS HEREBY STIPULATED AND AGREED THAT:

         1) This Protective Order will be entered pursuant to Rule 26(c) of the Federal Rules of Civil Procedure.

         2) The parties assert and stipulate that documents regardless of the medium or manner generated, stored or maintained (including, among other things, testimony, transcripts, or tangible things) potentially relevant to this litigation contain or constitute proprietary information such as compensation plans, company policies, collective bargaining agreements, company procedures, personal information related to Plaintiff (including health information and/or medical records), and other sensitive data and information that is not generally available in the public domain (“Confidential Information”). “Confidential Information” shall include: any type or classification of information, whether originals, copies, or in redacted form, or whether in oral deposition testimony (transcript or videotape); interrogatory responses or responses to request for admission consisting of business or financial records; documents containing trade secrets or proprietary information; personnel records; information about current, past, or prospective employees that is of a confidential or private nature, records or information on financial information of the parties; and any other writing as defined by the Rules of Evidence, reflecting confidential, commercial or personal information that counsel for any of the parties has in good faith designated as confidential. Subject to otherwise proper objections, the Parties agree to produce such documents in accordance with this Agreed Protective Order (“Order”).

         3) The protections conferred by this Stipulation and Order cover not only Confidential Information, but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties, counsel, or others permitted to review and/or access the Confidential ...


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