United States District Court, S.D. Ohio, Eastern Division
WILLIAM L. HANNA, AND CYNTHIA G. HANNA Plaintiffs,
WELLS FARGO BANK, N.A., Defendant.
J. TROUTMAN, ESQ.* WOMBLE BOND DICKINSON (US) LLP *ADMITTED
PRO HAC VICE ATTORNEYS FOR RESPONDENT WELLS FARGO BANK, N.A.
M. KOHL, ESQ., ANDREW J. GERLING, ESQ., BRIANA R.C. HART,
ESQ. DOUCET & ASSOCIATES, INC. COUNSEL FOR PLAINTIFFS
WILLIAM AND CYNTHIA HANNA
AGREED PROTECTIVE ORDER
Honorable Elizabeth Preston Deavers
HEREBY STIPULATED by and between Plaintiffs WILLIAM L. HANNA,
and CYNTHIA G. HANNA ("Plaintiffs") and Defendant
WELLS FARGO BANK, N.A. ("Wells Fargo"), through
their respective attorneys of record, as follows:
documents and information have been and may be sought,
produced or exhibited by and among the parties to this action
relating to trade secrets and confidential information, or
other proprietary information belonging to Wells Fargo.
documents and information related to Plaintiffs have been and
may be sought, produced or exhibited by and among the parties
to this action that is highly private, sensitive or protected
by law from public disclosure.
the parties have agreed that a Stipulated Confidentiality
Agreement ("Agreement") is necessary in this case
to prevent the unnecessary disclosure, use or dissemination
of such confidential information and the parties agree that
consent to the terms of this Agreement is a condition
precedent for the review of any documents produced pursuant
to this Agreement;
THEREFORE, in consideration of the mutual promises contained
herein, the parties stipulate and agree as follows:
Agreement shall govern the use, handling and disclosure of
all documents, testimony or information produced or given in
this action which are designated to be subject to this
Agreement in accordance with the terms hereof.
Designation of Information as Confidential.
Any party or nonparty producing documents or other materials
in this action may designate such materials and the
information contained therein subject to this Agreement by
typing or stamping on the front of the document, or on the
portion(s) of the document for which confidential treatment
is designated, "Confidential." Failure by the
Producing Party to designate any Discovery Material as
"Confidential" within thirty (30) days of its
production constitutes a waiver of any Party to declare that
Discovery Material as "Confidential."
Persons to Whom Confidential Information May be
document, transcript or pleading given confidential treatment
under this Agreement, and any information contained in, or
derived from any such materials (including but not limited
to, all discovery responses or deposition testimony that
refers, reflects or otherwise discusses any information
designated confidential hereunder) may not be disclosed other
than in accordance with this Agreement and may not be
disclosed to any person other than:
a) the parties, including employees of the parties, to the
extent reasonably necessary for the prosecution or defense of
claims or defenses in this Lawsuit;
b) counsel representing the parties and their support
personnel whose functions require access to such ...