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Superior Credit Union, Inc. v. Cumis Insurance Society, Inc.

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

July 25, 2019

SUPERIOR CREDIT UNION, INC. Plaintiff,
v.
CUMIS INSURANCE SOCIETY, INC. Defendant.

          Joseph L. Dilts, K. Roger Schoeni Patrick J. Collins, Esq., pro hac vice Patrice B. Collins, Esq., pro hac vice COLLINS & COLLINS, LLC Attorneys for Plaintiff

          Brandon McGrath Bingham Greenbaum Doll L.L.P. Attorneys for Defendant

          Susan J. Dlott Judge

          AGREED PROTECTIVE ORDER FOR THE PROTECTION OF CONFIDENTIAL INFORMATION

          Karen L. Litkovitz. Magistrate Judge

         Come now the parties, by and through their respective counsel, and with the permission of the Court, hereby agree as follows as to their Agreed Protective Order for the Protection of Confidential Information:

         Documents and information produced by a party in this litigation may be confidential and proprietary in nature. The revealing or dissemination of confidential documents or information by whatever means creates a risk that the documents or information will be obtained and used in a manner which would damage the interests of that party or another entity not a party to this action. Accordingly, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the following protective conditions shall apply to the conduct of discovery of proprietary or confidential information in this litigation.

         1. All documents and information produced by the parties in this litigation and labeled "confidential," including all personnel files, business records and financial records of which do not constitute public records, shall be maintained confidentially and used solely for the purposes of this action. This Agreed Order shall have no application to any information or document not so labeled.

         2. If the Producing Party believes that a document and/or information to be given or produced to the Receiving Party is confidential, the Producing Party may mark the document, article, or thing containing such information with the designation:

         CONFIDENTIAL

         Each page of multiple page documents shall separately be marked confidential.

         3. Access to and disclosure of information and/or documents designated as confidential pursuant to this agreement shall be limited to:

(a) the Court (including court personnel and court reporters);
(b) the parties;
(c) trial counsel of the Receiving Party and their respective staffs as well as ...

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