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Hanna v. Wells Fargo Bank, N.A.

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

May 15, 2018

WILLIAM L. HANNA, AND CYNTHIA G. HANNA Plaintiffs,
v.
WELLS FARGO BANK, N.A., Defendant.

          ERIC J. TROUTMAN, ESQ.* WOMBLE BOND DICKINSON (US) LLP *ADMITTED PRO HAC VICE ATTORNEYS FOR RESPONDENT WELLS FARGO BANK, N.A.

          SEAN 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

         IT IS 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:

         WHEREAS, 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.

         WHEREAS, 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.

         WHEREAS, 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;

         NOW, THEREFORE, in consideration of the mutual promises contained herein, the parties stipulate and agree as follows:

         1. This 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.

         2. 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."

         3. Persons to Whom Confidential Information May be Disclosed.

         Any 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 ...

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