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Fitzgerald v. The Kroger Co.

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

June 27, 2018

JEAN FITZGERALD, Plaintiff,
v.
THE KROGER CO., Defendants.

          John E. Quinn, Esq., J. Julius Bolock Esq.

          George C. Smith Judge.

          AGREED AND STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          Chelsey M. Vascura Magistrate Judge.

         WHEREAS, certain documents, information and other things arguably discoverable under applicable rules of discovery in this action should be kept confidential in order to protect the privacy or legitimate business interests of the parties; and

         WHEREAS, the parties to this action have agreed on the terms of a Stipulated Protective Order to govern the treatment, disclosure and dissemination of confidential documents and information both during the pendency of the action and following its termination, or until this Stipulated Protective Order is amended or superseded;

         IT IS HEREBY STIPULATED AND AGREED BY THE PARTIES, this Honorable Court consenting, that:

         1. This Agreed and Stipulated Confidentiality Agreement and Protective Order (hereinafter "Stipulated Protective Order") shall apply to and govern all documents, information and things produced in discovery in this action or any other proceedings herein which contain proprietary information, trade secrets, or other confidential information, research, development or commercial information. Such items may include, without limitation, documents and things produced, answers to interrogatories, answers to requests for admissions, information obtained from inspection of premises or things, and any other matter which the disclosing party shall designate as confidential pursuant to Paragraph 6 herein, as well as all information, documents and things referring or relating to the foregoing, including, but not limited to, copies summaries, digests, compilations or abstracts (all of which are referred to collectively herein as "PROTECTED MATERIAL").

         2. Except upon further Order of this Court, by express prior written consent of counsel for the producing party, or as otherwise provided herein, PROTECTED MATERIAL furnished in this action by any person or entity and information derived from PROTECTED MATERIAL shall be used solely for the purpose of the litigation of this action, and shall not be disclosed by the recipient to any person other than:

a. The parties and their attorneys, including the attorneys' paralegals, clerks, and court reporters, stenographic and word processing personnel, as necessary in connection with the prosecution or defense of this action;
b. Insurers and/or claims adjusters/administrators for the parties or other attorneys retained by insurers;
c. Current or former directors, officers, and employees of the parties as necessary to the prosecution or defense of this action;
d. A reasonable number of persons retained by the parties as expert consultants or expert witnesses in the prosecution or defense of this action; and
e. The Court.

         3. Each person who knowingly receives PROTECTED MATERIAL designated pursuant to this Stipulated Protective Order agrees to subject himself or herself to the jurisdiction of the Court in which this action is pending for the purpose of any proceeding to enforce performance under or compliance with this Stipulated Protective Order, or to address any alleged violation thereof. Any party to whom PROTECTED MATERIAL is ...


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