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Lindy v. Hills Property Management, Inc.

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

July 2, 2019

DONNA LINDY, Plaintiff,
v.
HILLS PROPERTY MANAGEMENT, INC. Defendant.

          Susan J. Dlott Magistrate Judge

          STIPULATED PROTECTIVE ORDER

          KAREN L. LITKOVITZ JUDGE

         By stipulation and agreement of the parties and pursuant to the Court's authority to regulate documents and proceedings before it, the Court enters this Protective Order pursuant to Federal Rules of Civil Procedure 26(c) and 29 regarding discovery of any form whatsoever that concerns the information listed below. This Protective Order is necessary to protect the confidences and proprietary interests of the parties, and the parties have agreed that confidential or proprietary documents and information should be kept confidential, used only for the purposes of litigation between these parties, and disclosed only to certain designated persons. The Court hereby orders that such discovery of the information listed below will be subject to the following terms and conditions:

         I. Definition of Confidential Information.

         The following shall constitute Confidential Information:

(a) Personnel information including, but not limited to, personnel files; documents or information that contain personnel information of any past, present, or prospective employees of Defendant (with the exception of Plaintiff Donna Lindy); performance ratings; supervisory notes, discipline reports, information relating to employment policies; and documents or information which the parties or the person(s) to which such information refers may claim, understand, or believe to be private, secret, or personal entrusted to someone in the course and scope of employment;
(b) Documents, lists and information containing the social security numbers, employee identification numbers, banking information, and any other information personal to the individuals listed;
(c) Non-public financial information including, but not limited to, information regarding earnings, profits, income, and/or financial status, including wage and benefit documentation or information regarding any employee or former employee of Defendant (with the exception of Plaintiff Donna Lindy);
(d) Information of Defendant that contains customer information, trade secrets, future business plans, market analysis, confidential research, development, commercial or other proprietary information, including but not limited to client contact information obtained during Plaintiffs employment with Defendant;
(e) Documents and/or information relating to any investigations or studies of any aspect of Defendant's business or operations by a third party consultant, person and/or entity;
(f) Any other information, documents, or things subject to protection under the law, including, but not limited to, Federal Rule of Civil Procedure 26;
(g) Any testimony specifically revealing Confidential Information as defined in Paragraphs l(a)-(e) above;
(h) Extracts and summaries prepared from such materials set forth in Paragraphs 1 (a)-(e) above; and
(i) Those portions of briefs, affidavits, and depositions, including exhibits thereto, which contain or restate the Confidential Information.

         2. Information that is not ...


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