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Griffin v. Darling Ingredients, Inc.

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

June 11, 2019

ROBERT A. GRIFFIN Plaintiff,
v.
DARLING INGREDIENTS, INC., et al. Defendants.

          Brian P. O'Connor (0086646), Charles E. Reynolds (0019935) SANTEN & HUGHES Attorneys for Plaintiff

          AGREED PROTECTIVE ORDER

          WALTER H. RICE, JUDGE

         Pursuant to Rule 26 of the Federal Rules of Civil Procedure and for good cause shown, the Plaintiff, Robert A. Griffin ("Plaintiff), and Defendants, Darling Ingredients, Inc., f/k/a Darling International, Inc., Griffin Industries LLC and Federal Insurance Company, d/b/a Chubb ("Defendants") hereby stipulate to the entry of the following Agreed Protective Order. Plaintiff and Defendants may be hereinafter collectively referred to as "the Parties," or individually as a "Party."

         This Agreed Protective Order is to preserve and maintain the confidentiality of certain personal and corporate proprietary and/or financial data ("Confidential Information") that may be disclosed or obtained by the Parties through testimony and/or the production of certain records by and between the Parties during the course of discovery. The Parties agree that good cause exists for this Agreed Protective Order to preserve the legitimate privacy interests of sources of Confidential Information that have not been released to the public and which the Parties may mutually seek production of through their respective discovery requests. The Court specifically finds that good cause exists for this Agreed Protective Order.

         1. This Agreed Protective Order shall govern the disclosure and use of Confidential Information produced in connection with this litigation. All information which is or has been produced or discovered in this litigation, regardless of whether designated CONFIDENTIAL as described below, shall be used solely for the prosecution or defense of this litigation unless the information is available to the general public without a breach of the terms of this Agreed Protective Order. The measures designated by the Parties in this Agreed Protective Order are reasonable and will not prejudice anyone or unduly burden the Court.

         2. This Agreed Protective Order is necessary to preserve the legitimate proprietary and privacy interests of sources of information and establishes a procedure for disclosing Confidential Information to the Parties in this litigation, imposes obligations on persons receiving Confidential Information to protect it from unauthorized use or disclosure, and establishes a procedure for challenging confidentiality designations.

         3. By entering into this Agreed Protective Order the Parties do not intend to waive any objections raised in response to discovery, nor does this Agreed Protective Order in any way obligate any Party to produce any specific documents or records in the future which a Party deems inappropriate for production.

         4. Any documents produced subject to the terms of this Agreed Protective Order shall be considered Confidential Information and shall be given confidential treatment as described below. All documents produced subject to this Agreed Protective Order shall be designated or stamped CONFIDENTIAL.

         5. Neither Party shall be obligated to challenge a CONFIDENTIAL designation at the time it is made, and failure to do so shall not preclude or prejudice a subsequent challenge thereto. In the event a Party disagrees at any stage with a CONFIDENTIAL designation, that Party shall provide to the disclosing Party written notice of its disagreement with the designation. The Parties shall first try to dispose of such dispute in good faith on an informal basis. If the dispute cannot be resolved, either Party may request appropriate relief from the Court by way of a further motion. Such relief may be requested on an expedited basis. The disclosing Party shall have the burden of proving that the information has been properly designated CONFIDENTIAL. In the event the Court determines that the contested information is not Confidential Information, the CONFIDENTIAL designation shall be deemed to have been removed from the subject document and information contained therein. Nothing herein shall prohibit either Party from seeking relief from the Court to remove a CONFIDENTIAL designation, nor shall it prohibit a Party from seeking to reinstate a CONFIDENTIAL designation that has been removed pursuant to this paragraph. Unless and until the CONFIDENTIAL designation is removed, or in the event such designation is reinstated, use of such Confidential Information shall be governed by the Agreed Protective Order, except to the extent otherwise ordered by the Court.

         6. Documents designated as CONFIDENTIAL will include documents containing sensitive personal or financial information, corporate proprietary and/or financial information, trade secrets, or commercially sensitive business information. Additional documents may be later identified which shall also be considered Confidential Information and such records shall be given similar protections pursuant to this Agreed Protective Order as specifically designated by the Parties during the course of this litigation.

         7. Confidential Information shall not be exhibited, disseminated, copied, or in any way communicated to anyone for any purpose whatsoever, other than in conjunction with this litigation.

         8. Neither the receiving Party nor its representatives shall disclose documents designated as CONFIDENTIAL, other than to the following persons:

a. All attorneys for the Parties, including in-house attorneys and outside counsel, and their assistants, associates, paralegals, clerks, stenographic personnel, and those individuals specifically acting at the direction of counsel;
b. The Parties, including representative employees of each Party or any of their designated counsel of ...

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