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Jamason v. Navistar International

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

June 17, 2019

DAMON JAMASON Plaintiff,
v.
NAVISTAR INTERNATIONAL Defendant,

         Removed from Court of Common Pleas of Clark County, Ohio, No. I9-CV-0034

          Matthew G. Bruce Matthew G. Bruce Evan McFarland Spitz Law Firm LLC Attorneys for Plaintiff .

          Douglas M. Oldham BARNES & THORNBURG LLP Attorney for Defendant.

          STIPULATED PROTECTIVE ORDER

          Walter H. Rice Judge.

         The parties assert that certain documents and information at issue in this case or sought by the parties in discovery contain confidential or proprietary information and require protection against unrestricted disclosure and use. The parties to this action have agreed to enter into this Protective Order to provide each other with protection against unrestricted disclosure and use. Therefore, it is hereby ORDERED as follows:

         1. CONFIDENTIAL documents, information, or testimony, for purposes of this Order, means any document, information, or testimony that has been designated by any party as CONFIDENTIAL or as part of the record regardless of whether said designation is made in sworn testimony, in documents produced in formal or informal discovery, at a hearing, trial, or in any documents submitted to the Court. CONFIDENTIAL documents may include, but are not necessarily limited to, confidential and proprietary business records, documents containing sensitive personal identifying information, or any document relating to a non-party employee of Defendant's.

         2. All documents, information, or testimony designated as CONFIDENTIAL shall be produced during discovery provided that: (a) such documents, information, and testimony shall be used and disclosed only in trial, preparation for trial, or any appeal in this action, shall not be used for competitive or business purposes and shall not be used or disclosed by any party or person subject to this Order for, any other purposes whatsoever and (b) all such documents and information or copies or written or typed summaries thereof will remain at all times during the course of this action in the custody of the parties' counsel (unless filed with the Court as described in paragraph 7 of this Order) until returned pursuant to paragraph 6 of this Order.

         3. Documents and information deemed by any party to be confidential under this Order shall have endorsed on the document and/or any copies provided to opposing counsel the word "CONFIDENTIAL." Testimony deemed to be confidential under this Order shall be so designated on the record and such testimony shall be separately recorded and maintained by the stenographic reporter subject to the other provisions of this Order. The failure to challenge the designation of CONFIDENTIAL at the time of its disclosure shall not be deemed a waiver of the right to challenge the propriety of such designation any time thereafter. The failure to designate documents, information, or testimony as CONFIDENTIAL at the time of production or revelation shall not preclude later designation. From the time such post-production or post-revelation designation is made, it shall have the same effect as if each individual item designated on a post-production or post-revelation basis was in fact designated as set forth in this paragraph at the time of production or revelation. Notice of such post-production or post-revelation designation shall be given in writing to all parties to whom such documents, information, or testimony has previously been furnished.

         4. Documents or the substance or contents of documents and information designated as CONFIDENTIAL as well as all notices and memoranda relating thereto, and information derived therefrom, shall be used and disclosed only in trial, preparation for trial, including but not limited to use during depositions, or any appeal in this action and only to the following persons:

(a) The parties and counsel for the parties;
(b) Experts or other individuals retained or otherwise engaged by either party for purposes of testifying in this action;
(c) Employees of counsel of record for the parties or associate or co-counsel of the parties or testifying experts who provide services of any kind for purposes of trial, preparation for trial, or appeal in this action;
(d) Judges and juries and stenographic reporters to the extent necessarily incident to trial, preparation for trial, or appeal.

         The parties agree that disclosure to the persons described in (a)-(c) above is conditioned upon those persons being bound by the terms of this Order. The parties further agree that disclosure by counsel to any person described in (b) above is conditioned upon that person having executed the agreement attached as Exhibit A hereto and that ...


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