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Riley v. Mercy Health Physicians Cincinnati LLC

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

June 18, 2018

TINA M. RILEY, Plaintiff,
v.
MERCY HEALTH PHYSICIANS CINCINNATI, LLC, Defendant

          Kenneth G. Hawley, Esq. (0031772) Hawley Law Co., LPA Counsel for Plaintiff

          Mercy Health Thomas J, Wiencek Counsel for Defendant

          STIPULATED PROTECTIVE ORDER

          Susan J. Dlott Judge

         The parties to this Stipulated Protective Order have agreed to the terms of this Order; accordingly, it is ORDERED:

         I. Scope.

         All documents produced during discovery, all responses to discovery request, all deposition testimony and exhibits, other materials which may be subject to restrictions on disclosure for good cause and information derived directly therefrom (hereinafter collectively "documents"), shall be subject to this Order concerning confidential information and as set forth below. As there is a presumption in favor of open and public judicial proceedings in the federal courts, this Order shall be strictly construed in favor of public disclosure and open proceedings whenever possible.

         2. Form and Timing of Designation.

         A party may designate documents as confidential and restricted in disclosure under this Order by placing or affixing the words "CONFIDENTIAL" on the document in any manner that will not interfere with the legibility of the document that will permit complete removal of the CONFIDENTIAL designation. Documents shall be designated CONFIDENTIAL prior to or at the time of the production or disclosure of the documents. The designation "CONFIDENTIAL" does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order.

         3. Documents Which May be Designated CONFIDENTIAL.

         Any party may designate documents as CONFIDENTIAL upon making a good faith determination that the documents contain information protected from disclosure by statute or that should be protected from disclosure as confidential personal information, medical or psychiatric information, trade secrets, personnel records not otherwise a public record or such other sensitive commercial information that is not publicly available. Public records and other information or documents that are publicly available may not be designated as CONFIDENTIAL. The protections conferred by this Order cover not only documents and information as provided herein, but also (1) any information copied or extracted from said material; (2) all copies, excerpts, summaries, or compilations of said material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal said material.

         4. Depositions.

         Deposition testimony shall be deemed CONFIDENTIAL only if designated as such. During any deposition, either party may designate on the record that certain line of questioning and corresponding answers is confidential and those portions of the deposition testimony will be treated as confidential by both parties until 10 days after receipt of transcript, at which time the designating party shall specifically identify the page number(s) of the transcript which are to be designated as CONFIDENTIAL. Thereafter, the deposition transcripts and any those portions so designated shall be protected as CONFIDENTIAL, pending objection, under the terms of this Order.

         5. Protection of Confidential Material.

         (a) ...


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