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Kemp v. J.J.B. Hilliard, W.L. Lyons, LLC

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

June 3, 2019

JAMES KEMP Plaintiff,
v.
J.J.B. HILLIARD, W.L. LYONS, LLC Defendant.

          David K. Montgomery (0040276), Gabriel M. Fletcher (0096916), JACKSON LEWIS, P.C. Counsel for Defendant

          Mark J. Byrne (0029243), JACOBS, KLEINMAN, SEIBEL & McNALLY, LPA Counsel for Plaintiff

          STIPULATED PROTECTIVE ORDER

          MICHAEL R. BARRETT, UNITED STATES DISTRICT JUDGE

         The parties to No. 1:18-CV-00746, James Kemp (“Plaintiff”) and J.J.B. Hilliard, W.L. Lyons, LLC (“Defendant”), stipulate and agree as follows and the Court enters the following Stipulated Protective Order designed to protect the parties' legitimate concerns of confidentiality.

         1. The parties expect that this case may involve confidential personal or business information related to Plaintiff, Defendant and/or non-party individuals. Whenever counsel for the producing party believes in good faith that the discovery information contains confidential business or personal information (hereinafter referred to as “Confidential Information”), then counsel may designate such information as “Confidential, ” in which event such information may only be disclosed to or used by a “Qualified Person” as defined in Paragraph 3. The parties have agreed that such information shall be maintained confidentially.

         2. All Confidential Information produced or provided by any party or by any witness through discovery in this action shall be used only for the purposes of preparing for and conducting litigation proceedings in this action in the manner prescribed herein and for no other purpose.

         3. “Qualified Persons” shall include the following:

(i) Any party to the action;
(ii) Counsel of record for the parties in this action and all other attorneys, paralegals, stenographic and clerical employees of the law firm(s) of such counsel of record assisting in the prosecution or defense of this action;
(iii) Independent experts, consulting firms, or other independent contractors who are not regular employees of a party hereto but who are assisting counsel of record in the prosecution or defense of this action and who have each signed an affidavit in the form of Exhibit A attached hereto;
(iv) Any deponent in this action who, in the good-faith opinion of counsel, must be shown the contents of any document or other Confidential Information subject to this Order in prosecution or defense of this action and who have each signed an affidavit in the form of Exhibit A attached hereto;
(v) Any witness at the trial of this action who, in the good-faith opinion of counsel, must be shown the contents of any documents or other Confidential Information subject to this Order in prosecution or defense of this action;
(vi) Court personnel or any arbitrator or mediator assigned ...

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