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Roberts v. Crane Pumps & Systems, Inc.

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

June 20, 2019

JAMES ROBERTS, Plaintiff,
v.
CRANE PUMPS & SYSTEMS, INC., Defendant.

          James J. Hux, HUX LAW FIRM, LLC, Attorney for Plaintiff

          Chad J. Kaldor, Sarah K. Squillante, LITTLER MENDELSON, P.C., Attorneys for Defendant

          Thomas M. Rose Judge.

          STIPULATED PROTECTIVE ORDER

          Michael J. Newman United States Magistrate Judge.

         The parties to this action, Plaintiff James Roberts and Defendant Crane Pumps & Systems, Inc., subject to the approval of the Court, agree to the following Order relating to all discovery that one or more parties claim to be or to reveal trade secrets, proprietary information, and/or confidential information, including, but not limited to, confidential personnel information, and business and financial information.

         The parties agree that this Order will expedite and facilitate discovery, and provides reasonable and appropriate protection for confidential information and materials without impeding the parties' discovery and litigation involved in this action.

         IT IS HEREBY ORDERED:

         1. Confidential Information-Defined: Any information produced by the parties during the course of discovery that is not generally known by or disclosed to the public, and all copies, excerpts, or summaries of the documents produced, including without limitation, documents produced by a party pursuant to the Federal Rules of Civil Procedure, answers to requests for admission, answers to interrogatories, documents subpoenaed from a third party in connection with deposition testimony or otherwise, and deposition transcripts, may be designated as “Confidential” by any party. Any matter designated by a party as “Confidential” may only be disclosed to the following persons:

(a) The parties and attorneys of record for the parties in this action, the staff of their respective law firms, and, in the case of the corporate parties, their in-house counsel and in-house counsel's administrative and paralegal assistants;
(b) Experts or consultants hired by or consulted by such attorneys in connection with this case but only on the condition that the expert or potential expert agrees to the restrictions set forth in this Order;
(c) Persons noticed for deposition or witnesses, to the extent necessary for the preparation of the person's testimony in this case, provided that documents will not be shown to witnesses who are or were not employees of the producing party (or otherwise within the categories of persons to whom disclosure may be made) except during depositions or solicitation of testimony;
(d) The Court and Court personnel; and
(e) Stenographic reporters engaged for depositions or other proceedings necessary for the conduct of this case.

         2. Any party from time to time may designate as “Confidential” any discovery materials they produce which contain confidential information (hereinafter “Confidential Discovery Materials”), the disclosure of which by the receiving party would, in good faith judgment of the party producing such material, result in disclosure of confidential commercial information or undue invasion of privacy and is ...


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