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Rosemeyer v. E.W. Scripps Co.

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

January 10, 2020

JOSEPH ROSEMEYER, Plaintiff,
v.
THE E.W. SCRIPPS COMPANY AND SCRIPPS MEDIA, INC. dba WCPO-TV Defendants.

          David A. Eberly (0067007) Eberly McMahon Copetas LLC, Attorney for Plaintiff.

          M. Scott McIntyre (0075298), Jonathan M. Kelly (0095738), Baker & Hostetler LLP, Attorneys for Defendants.

          STIPULATED PROTECTIVE ORDER

          MATTHEW W. McFARLAND UNITED STATES DISTRICT COURT JUDGE

         Under Fed.R.Civ.P. 26 (c) and the stipulation of Plaintiff and Defendants (collectively, the “Parties” and individually, the “Party”), the Court enters this Stipulated Protective Order (“Order”). It is hereby ORDERED THAT:

         1. This Order shall govern the handling of documents, depositions, exhibits, and other written, recorded, electronic or graphic matter produced in discovery, whether pursuant to a formal or informal request, letter, or subpoena, a request made or question asked at any deposition, or any other means (collectively, the “Information”). Designation of documents and things as Confidential shall be as limited as possible and shall be performed in good faith to the opposing party, counsel, and the Court. All non-designated matters shall be handled in the ordinary manner through the Civil Rules.

         2. The Parties may designate Information as Confidential Information (“Confidential Information”) upon a good faith assertion that such materials or testimony constitute Information that is not generally known, not otherwise publicly available, and which that Party would not ever reveal to third parties, including but not limited to sensitive financial data, technical information, medical or psychological records, current employment records, prior family legal matters, propriety or nonpublic information, contracts or commercially and/or completely sensitive information. “Confidential Information” further includes Information that a Party has treated as confidential and is not subject to public disclosure and any other Information that would qualify as confidential under any legal standard. Any “Confidential Information” so designated shall only be used in connection with these proceedings and shall not be disclosed or utilized in any other respect, except as may be otherwise provided for in this Order or by law. Information that is available generally within the industry, freely available on the internet or by other media without restriction is not Confidential Information.

         3. The designation of the Information as “Confidential Information” for purposes of this Order shall be made as follows:

(a) In the case of party documents, by stamping, without obscuring the text, each page of such Information answers to interrogatories, other written materials (apart from depositions, other pretrial testimony, transcripts thereof and exhibits thereto), by stamping each page of such as “Confidential Information” or “Confidential” or “Confidential, Subject to Protective Order, ” or some similar or comparable designation.
(b) In the case of answers to interrogatories, other written materials (apart from depositions, other pretrial testimony, transcripts thereof and exhibits thereto), by stamping, without obscuring the text, the confidential portion of the Information or, where an entire page is confidential, each page of such Information with “Confidential Information” or “Confidential” or “Confidential, Subject to Protective Order, ” or some similar or comparable designation.
(c) In the case of depositions, other pretrial testimony, the transcripts thereof, and exhibits thereto, by a statement on the record by counsel for the party making the disclosure at the time of such disclosure, identifying the beginning and the end of the confidential disclosure, or with regard to the confidential portion of the transcript at any time up to 14 days after said party has received a transcript of the testimony.
(d) In the case of documents produced by a non-party, by a written statement from counsel specifically designating the Information to be “Confidential Information” or by stamping each page of such as “Confidential Information” or “Confidential” or “Confidential, Subject to Protective Order, ” or some similar or comparable designation.

         4. Whenever any “Confidential Information” is disclosed or used at a deposition or other pretrial testimony in this action, (i) each portion of any such testimony in which the “Confidential Information” is disclosed or used shall be conducted with only those persons in attendance who are authorized under this Order to have access to such “Confidential Information”; (ii) the transcript of the confidential portion and all confidential exhibits shall be marked “Contains Confidential Information -- Subject to Protective Order” (or comparable language), and shall thereafter be deemed to be fully subject to the provisions of this Order; and (iii) the transcript containing Confidential Information and exhibits designated as Confidential Information shall not be filed with this Court except in accordance with Paragraph 5 below.

         5. In the event a party wishes to file any “Confidential Information” with the Court for any purpose, prior to seeking permission to file Confidential Information under seal, and if time permits, the parties, through counsel, will discuss the Confidential Information and documents they intend to file in order to determine if a compromise can be reached in whole or in part to allow for filing not under seal. Unless resolved as set forth above, the party intending to file any designated “Confidential Information” under seal or not under seal must first file a motion under S.D. Ohio Civ. R. 5.2.1 for the Court to determine whether such pleading, deposition, or confidential portion thereof must be filed under seal in accordance with the provisions of S.D. Ohio Civ. R. 5.2.1. The Court shall determine whether the documents are appropriately filed under seal. If the Court grants the party's motion, the information filed with the court shall be filed in a sealed, opaque container or envelope with instructions to the Clerk of the Court to place such documents or other materials or things under seal with the following legend on the container or envelope:

(a) Bearing (1) the date of this Order; (2) the name, address and telephone number of filing counsel; (3) the caption of ...

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