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Deliotte v. Conair Corp.

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

January 16, 2020

Sylia Deliotte, et al. Plaintiffs,
v.
Conair Corporation, Defendant.

          William W. Patmon, III PATMON LAW FIRM LLC Counsel for Plaintiffs

          Matthew L. Schrader Reminger Co., L.P.A. Counsel for Defendant

          Graham Judge

          STIPULATED PROTECTIVE ORDER

          ELIZABETH A. PRESTON DEAVERS MAGISTRATE JUDGE DEAVERS

         The Parties to this Stipulated Protective Order have agreed to the terms of this Order; accordingly, it is ORDERED:

         1. Scope. All documents produced in the course of discovery, including all responses to discovery requests, all deposition testimony and exhibits, other materials which may be subject to restrictions on disclosure for good cause and information derived directly therefrom (hereinafter collectively “documents”), shall be subject to this Order concerning confidential information as set forth below. As there is a presumption in favor of open and public judicial proceedings in the courts, this Order shall be strictly construed in favor of public disclosure and open proceedings wherever possible. The Order is also subject to the Local Rules of this Court and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. Form and Timing of Designation. A party may designate documents as confidential and restricted in disclosure under this Order by placing or affixing the words “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” on the document in a manner that will not interfere with the legibility of the document and that will permit complete removal of the CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER designation. Documents shall be designated CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER prior to or at the time of the production or disclosure of the documents. The designation “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order.

         3. Documents Which May be Designated CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. Any party may designate documents as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER only: (a) upon making a good faith determination that the documents contain information protected from disclosure by statute or that should be protected from disclosure as confidential personal information, medical or psychiatric information, employment or personnel records, trade secret or proprietary information, or such other sensitive information that is not publicly available; and, (b) if the designating party treats or has treated such documents as confidential in the ordinary course of its business and reasonably believes in good faith that such documents must not be disclosed to third parties in order to protect a legitimate and reasonable confidentiality interest of the designating party. Public records and other information or documents that are publicly available may not be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.

         4. Depositions. Deposition testimony shall be deemed CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER only if designated as such by a party upon: (a) making a good faith determination that the testimony includes information protected from disclosure by statute or that should be protected from disclosure as confidential personal information, medical or psychiatric information, employment or personnel information, trade secret or proprietary information, or such other sensitive information that is not publicly available; and, (b) if the designating party treats or has treated such documents as confidential in the ordinary course of its business and reasonably believes in good faith that such documents must not be disclosed to third parties in order to protect a legitimate and reasonable confidentiality interest of the designating party. Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. Thereafter, the deposition transcripts and any those portions so designated shall be protected as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER, pending objection, under the terms of this Order.

         5. Protection of Confidential Material.

         a. General Protections. Documents designated CONFIDENTIAL -SUBJECT TO PROTECTIVE ORDER under this Order shall not be used or disclosed by the Parties, counsel for the Parties, or any other persons identified in ¶ 5(b) for any purpose whatsoever other than to prepare for and to conduct discovery and trial in this action, including any appeal thereof.

         b. Limited Third-Party Disclosures. The Parties and counsel for the Parties shall not disclose or permit the disclosure of any CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER documents to any third person or entity except as set forth in subparagraphs (1)-(5). Subject to these requirements, the following categories of persons may be allowed to review documents that have been designated CONFIDENTIAL -SUBJECT TO PROTECTIVE ORDER:

         1) Counsel. Counsel for the Parties and employees and agents of counsel who have responsibility for the preparation and trial of the action;

         2) Parties. Parties and employees of a ...


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