Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Wilson v. Gregory

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

February 26, 2018

SARAH WILSON, et al. Plaintiff,
v.
ERIC GREGORY, et al. Defendants.

          Jennifer L. Branch, Trial Attorney for Plaintiff Alphonse A. Gerhardstein (0032053), Janaya Trotter Bratton (0084123), Attorney for Plaintiff Gerhardstein & Branch Co. LPA

          D. VINCENT F ARRIS CLERMONT COUNTY PROSECUTOR G. Ernie Ramos Jr. (0016709), Jeannette E. Nichols (0071627), Jason A. Fountain, Kimberly A. Rutowski (0076653) HARDIN, LAZARUS & LEWIS Counsel for Defendants

          STIPULATED PROTECTIVE ORDER FOR THE PROTECTION OF CONFIDENTIAL INFORMATION

          TIMOTHY S. BLACK, UNITED STATES DISTRICT JUDGE

         Undersigned counsel, on behalf of their respective parties move the Court to enter into the following protective order ("Order"). The Order is made pursuant to Rule 26(c) of the Federal Rules of Civil Procedure to limit the disclosure of discovered information, for the protection of third parties, and to preserve confidentiality of certain matters. The parties agree to be bound by the restrictions of this Order, limiting the use of such information as hereinafter provided from the date that each party signs this order.

         Each party signing this Order and anyone else who may subscribe to this Order agrees as follows:

         INFORMATION SUBJECT TO THIS ORDER

         1. This stipulated protection order covers all medical and mental health records produced for Jack Huelsman, Cheryl Huelsman, any Plaintiff or any Defendant, which have been or will be produced in discovery in this case. These records shall be subject to discovery between and among the parties but shall otherwise be kept confidential.

         2. Any party or non-party that produces information as to which it then has a reasonable good faith basis in law and fact to believe is of the type described in Paragraph 1, at the time of production, shall designate such information "confidential." Information so designated (hereinafter "confidential information") shall thereafter be subject to the provisions of this Order.

         3. Confidential information, as described in this section, shall, if in writing, be stamped on the face of the writing, or shall otherwise be clearly marked "confidential."

         4. Parties may designate as confidential information referenced at any deposition or portion thereof by making such designation on the record at the time of the deposition. If no confidential designation is made during a deposition, the contents shall be treated as confidential under this Order until 15 days after receipt of the transcript. Within that period, any party wishing to designate all or any portion of the deposition transcript as confidential shall make the appropriate designation in writing and then serve that designation by electronic or U.S. mail upon counsel for all parties. However, if no party orders a copy of the transcript at the time of the deposition or within 5 business days of the deposition, the contents of the deposition in its entirety shall be treated as confidential up to and until a copy of the same is ordered.

         5. In the event of an inadvertent disclosure of confidential information without proper designation, the disclosing party shall inform the other party of the error. Inadvertent failure to designate any information pursuant to this Order shall not constitute a waiver of any otherwise valid claim for protection, so long as such claim is asserted within thirty (30) days of the discovery of the inadvertent disclosure. Following discovery of the inadvertent disclosure, the disclosing party shall provide within three (3) business days a properly designated set of such confidential information to the other party, whom shall destroy copies of the improperly designated documents and certify such destruction to the disclosing party.

         6. Confidential information protected by this Order may be disclosed only to:

a. Counsel of record;
b. Members of the legal, paralegal, secretarial, and clerical staff ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.