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Casarez v. Producers Service Corp.

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

March 28, 2018

Jesus Casarez, Plaintiff,
v.
Producers Service Corp., Defendant.

          Brendan P. Feheley (0079107) Jason H. Beehler (0085337) Kegler Brown Hill Ritter Co., LPA Attorneys for Defendant

          Robert E. DeRose (0055214) Robi J. Baishnab (0086195) Local Counsel for Plaintiff

          Chris Burks (pro hac vice pending) Sean Short (pro hac vice pending) Sanford Law Firm, PLLC Attorneys in Charge for Plaintiffs

          Edmund A. Sargus, Jr. Chief Judge

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

          KIMBERLY A. JOLSON UNITED STATES MAGISTRATE JUDGE

         WHEREAS, certain documents, materials, discovery responses, testimony, admissions, data, and other materials and their contents, which may be requested through the above-captioned case (hereafter "the Lawsuit”) may contain confidential and proprietary information, including without limitation client or customer lists and information, confidential compensation information, confidential financial and business information, as well as other confidential information.

         It is hereby ORDERED that the following terms and conditions shall govern the disclosure and use of confidential information in this Lawsuit.

         1. To preserve the legitimate proprietary and privacy interests of sources of information, this Order establishes a procedure for disclosing Confidential Information (defined in Paragraph 2 below) to the parties in this Lawsuit, imposes obligations on persons receiving Confidential Information to protect it from unauthorized use or disclosure, and establishes a procedure for challenging confidentiality designations. This Order applies only to information furnished by parties and non-parties that is not otherwise publicly available and properly designated under this Order.

         2. This Order covers information that the producing or disclosing party or nonparty (hereinafter “source”) designates in good faith as “Confidential” or “Attorney's Eyes Only” (collectively, referred to as “Confidential Information”). The parties to this Agreement further agree that they will use “Confidential Information” material or information solely for the purposes of facilitating the prosecution or defense of this Lawsuit and not for any business or other purpose.

         3. The designation “Confidential” shall be limited to information that the source reasonably and in good faith believes is of a proprietary or commercially sensitive nature, or should otherwise be subject to confidential treatment. The designation “Confidential” shall also include information the source reasonably and in good faith believes is subject to protection under the confidentiality provisions of any state or federal act, law, or statute. All materials produced in this Lawsuit containing the designation “Confidential” shall be used solely for the purposes of this Lawsuit and shall be returned to the source or destroyed at the end of this Lawsuit.

         4. The designation “Attorney's Eyes Only” shall be limited to information that the source reasonably and in good faith believes (a) to contain highly sensitive trade secrets and proprietary information of the highest level of sensitivity, and (b) to carry a substantial likelihood of competitive damage if it were disclosed to any other person or entity.

         5. To designate information as “Confidential” or “Attorney's Eyes Only, ” a source must so mark it or, in the case of a deposition or hearing transcript, designate it as provided in paragraphs 11 and 12 herein, respectively. Either designation may be withdrawn by the source. The source must mark each page of each document and/or each significant component of any other object containing Confidential Information with the appropriate designation as required. A cover letter can be used, if appropriate, to designate material provided in a computerized format as “Confidential Information.”

         6. Accidental disclosure of Confidential Information without a designation does not alone waive the confidence and protections provided under this Order. Upon a source's discovery that information was not correctly designated, the source shall provide notice to the parties or other party that the information was inappropriately designated or inadvertently not designated. The party to whom the inadvertent disclosure was made shall then immediately return such material and all copies the party made thereof. Also, in the event any party hereto receives any document from another party or third-party that upon its face is subject to the attorney-client privilege, attorney work product doctrine, or any other privilege, that party shall immediately notify the producing party or third-party and return such document and all copies the party made thereof if so requested by the party or third-party who produced the document. The source shall then have seven business days in which to redesignate the information after which the terms of this Order shall apply. In the interim, the information may not be used in a manner inconsistent with the notice.

         7. Subject to the provisions of Paragraph 9, information designated as “Confidential” may ...


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