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S&S Healthcare Strategies, Ltd. v. Three Rivers Provider Network, Inc.

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

May 14, 2018

S&S HEALTHCARE STRATEGIES LTD, Plaintiff,
v.
THREE RIVERS PROVIDER NETWORK, INC., Defendant.

          Peter A. Saba, Jeffrey M. Nye Stagnaro, Saba & Patterson Co., LPA Counsel for S&S Healthcare

          Maureen A. Bickley Stephen R. Hernick Frost Brown Counsel for Three Rivers Provider Network

          William O. Bertelsman Judge

          AGREED PROTECTIVE ORDER

          KAREN L. LITKOVITZ MAGISTRATE JUDGE

         The parties have agreed to entry of this Order protecting the confidentiality of certain proprietary business information. Pursuant to the Federal Rules of Civil Procedure, the parties agree that all information exchanged during the course of discovery in this matter may be protected against unnecessary disclosure as follows:

         1. Scope of Order.

         This Order shall govern all materials produced by the parties in response to any formal discovery requests in this action (including, but not limited to, deposition testimony, documents produced or things inspected pursuant to Rules 26, 34, or 45 of the Federal Rules of Civil Procedure, answers to requests for admissions, and answers to interrogatories), or any information contained in those materials, and all copies, excerpts, or summaries of those materials (collectively, "Discovery Material").

         2. Non-Partv Discovery Material.

         This Order shall also govern all Discovery Material produced during discovery by any non-parties, but only when a party or producing non-party requests the protections provided by this Order.

         3. "Confidential" Discovery Material.

         (a) Any Discovery Material produced by any party throughout this litigation, which the party in good faith deems to be confidential, may be designated as confidential ("Confidential Discovery Material"). A party wishing to designate any Discovery Material as Confidential shall do so by marking it "Confidential" on its face, on the electronic media containing the Discovery Material, in the name of the electronic folder containing the Discovery Material, or by any other means reasonably sufficient to place the receiving party on notice that the Discovery Material is intended to be designated as Confidential. Once Discovery Material is designated as Confidential Discovery Material, it is expressly subject to this Order. All Discovery Material produced without an express designation of confidentiality shall not be subject to this Order.

         (b) Deposition testimony may also be designated confidential by an indication on the record at the deposition, or by written notice within a reasonable time of not less than 10 days following the date of the deposition. Each party shall attach a copy of such written notice or other label or legend to any copies of the depositions in its possession, custody, or control. Any deposition testimony designated as confidential shall constitute Confidential Discovery Material, as that term is defined in this Order. All depositions or portions thereof for which confidentiality is requested on the record shall be treated as confidential for a period of at least 10 days after the deposition transcript is available.

         (c) Confidential Discovery Material may be used solely for purposes of this litigation, and may not be used ...


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