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Myers v. Quest Building Services Ltd.

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

July 2, 2019

CINDY MYERS, Plaintiff,
v.
QUEST BUILDING SERVICES LTD, et at, Defendants.

          Matthew J.P. Coffman Coffman Legal, LLC Peter Contreras Contreras Law, LLC Attorneys for Plaintiff, Cindy Myers

          Scott H. DeHart Drew C. Piersall Zashin & Rich Co., LPA Attorneys for Defendants

          MORRISON MAGISTRATE JUDGE

          STIPULATED PROTECTIVE ORDER

          PRESTON DEAVERS U.S. DISTRICT MAGISTRATE JUDGE.

         This case is before the Court on the parties' joint motion to approve a proposed Stipulated Protective Order pursuant to Fed.R.Civ.P. 26(C). The Court finds that the discovery in this action will require the production of documents and things and testimony containing confidential, sensitive, and/or proprietary information requiring protection against unrestricted disclosure and use. In the interest of expediting discovery and limiting disputes regarding access to such information, the below is hereby stipulated and agreed to, by and among each of the parties in the above-entitled action ("the Action"), through their undersigned counsel.

         The joint motion is therefore GRANTED.

         IT IS ORDERED, ADJUDGED AND DECREED that:

         1. Scope of Protective Order

         a. This Protective Order shall be applicable to and shall govern without limitation all documents, materials, and information produced in response to initial disclosures, requests for production of documents and things, interrogatory answers, responses to requests for admissions, deposition testimony and exhibits, any other discovery authorized by the Federal Rules of Civil Procedure, court testimony, and matters of evidence in connection with the Action.

b. This Protective Order shall not be construed to apply to information which:
i. Is or becomes publicly known through no fault of the Receiving Party (unless such disclosure violates any other agreements to keep such information confidential); or
ii. The Receiving Party or its counsel has lawfully obtained outside of the discovery authorized by the Federal Rules of Civil Procedure.

         2. Designated Material.

         a. Any party or non-party with a reasonable, good faith belief that any documents, materials, or information produced in this case are confidential may, at the time of production, and by written notice as described herein, designate such documents, materials, or information as "Confidential" or "Highly Confidential." The information so designated, collectively referred to herein as "Designated Material," shall thereafter be subject to the provisions of this Protective Order. A party making such designation shall be referred to herein as the "Designating Party." A party receiving such Designated Material shall be referred to herein as the "Receiving Party."

         b. For purposes of this Protective Order, the term "Confidential" shall mean any and all documents, materials, or information concerning the business or affairs of any party to the Action acquired in the course of the party's respective work that such party believes in good faith would qualify for a protective order if sought from the Court.

         c. For purposes of this Protective Order, the term "Highly Confidential" shall mean any and all material that qualifies as "Confidential" and further relates to the parties' trade secrets; customer or client information; prospective customer proposals; medical or psychiatric information; information protected by the Health Insurance Portability and Accountability Act ("HIPAA"), Americans with Disabilities Act ("ADA"), or Family and Medical Leave Act ("FMLA") or applicable privacy laws; or other highly sensitive information that is not publicly available.

         3. Methods of Designating.

         Any documents, materials, or information to be designated Confidential or Highly Confidential may be so designated by:

a. Affixing the legend "Confidential" or "Highly Confidential" on such documents, materials, or information prior to their production. Stamping such a legend on the cover of any multi-page document shall designate all pages of such document, unless otherwise indicated by the Designating Party;
b. Furnishing a separate written notice to the counsel for the Receiving Party regarding such documents, materials, or information, at the time of their production or as soon thereafter as practicable, specifically identifying the documents, materials, or information to be so designated (for example, by identifying the document number(s)) and their respective designations; or
c. All testimony, documents, material, or information disclosed at a deposition may be designated as Confidential or Highly Confidential by making such designation on the record at the time of the deposition, or by subsequently notifying counsel of deposition testimony or ...

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