Finley v. Seven Hills OB-GYN Assoc.
Finley v. Seven Hills OB-GYN Assoc.
Trial Court Opinion
UNITEDSTATES DISTRICTCOURT SOUTHERNDISTRICTOFOHIO WESTERN DIVISION NICOLEFINLEY, : : Plaintiff(s), : CaseNo.1-22-cv-00720 : Judge: MatthewW. McFarland v. : MagistrateJudge: Karen L.Litkovitz : SEVENHILLS OB-GYNASSOCIATES, : LLC : Defendant(s). : : STIPULATEDPROTECTIVE ORDER Pursuant to the parties’ joint request that the Court enter this Order, and their agreement thatthefollowinglimitationsandrestrictionsshouldapplytodocumentsandinformationproduced for inspection and copying during the course of this litigation (the “Action”), the Court hereby ORDERS that: 1. Scope. This Protective Order (hereinafter “Protective Order” or “Order”) shall applytoalldocumentsorotherinformationproducedinthecourseofdiscoveryinthisActionthat the producing person or entity (the “Producing Entity”) has designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” or “ATTORNEYS’ EYES ONLY – SUBJECT TO PROTECTIVE ORDER” (either a “Confidentiality Designation” or collectively the “Confidentiality Designations”) pursuant to this Order, including but not limited to, all initial disclosures, all responses to discovery requests, all deposition testimony and exhibits, and all materials (including documents or testimony) produced by non-parties in response to subpoenas issued in connection with this matter, including all copies, excerpts, and summaries thereof (collectively the“Confidential Information”). 2. Purpose.ThepurposeofthisProtectiveOrderistoprotectagainsttheunnecessary disclosureofConfidential Information. 3. Disclosure Defined. As used herein, “disclosure” or “to disclose” means to divulge, reveal, describe, summarize, paraphrase, quote, transmit, or otherwise communicate Confidential Information, and the restrictions contained herein regarding disclosure of
Confidential Information also apply with equal force to any copies, excerpts, analyses, or summaries of such materials or the information contained therein, as well as to any pleadings, briefs, exhibits, transcripts or other documents which may be prepared in connection with this litigation whichcontain orreferto theConfidential Information orinformationcontainedtherein. 4. DesignatingMaterial a. Designating Material As Confidential: Any party, or any third party subpoenaed by one of the parties, may designate as Confidential and subject to this ProtectiveOrderanydocuments,testimony,writtenresponses,orothermaterialsproduced in this case if they contain information that the Producing Entity asserts in good faith is
protected from disclosure by statute or common law, including, but not limited to, confidential personal information, medical or psychiatric information, trade secrets, personnel records, or such other sensitive commercial information that is not publicly available.InformationthatispubliclyavailablemaynotbedesignatedasConfidential.The designationofmaterialsasConfidentialpursuanttothetermsofthisProtectiveOrderdoes not mean that the document or other material has any status or protection by statute or otherwiseexcept to theextentandforthepurposesofthis Order. b. Designating Material As Attorneys’ Eyes Only. Any party, or any third partysubpoenaedbyoneoftheparties,maydesignateasAttorneys’EyesOnlyandsubject to this Protective Order any materials or information that meet the test set forth in Paragraph 4.a, but as to which the Producing Entity also asserts in good faith that the information is so competitively sensitive that the receipt of the information by parties to thelitigationcould result in competitiveharm to theProducingEntity. 5. Form and TimingOfDesignation.
a. DocumentsAndWrittenMaterials.TheProducingEntityshalldesignate anydocument orother writtenmaterials as confidential pursuant to this Orderbymarking each page of the material with a stamp setting forth the Confidentiality Designation, if practical to do so. The person or entity designating the material shall place the stamp, to the extent possible, in such a manner that it will not interfere with the legibility of the document. Materials shall be so-designated prior to, or at the time of, their production or disclosure. b. Electronically Stored Information (“ESI”): If a production response includes ESI, the Producing Entity shall make an effort to include within the electronic
files themselves the Confidentiality Designation to the extent practicable. If that is not practicable, then the Producing Entity shall designate in a transmittal letter or email to the party to whom the materials are produced (the “Receiving Party”) using a reasonable identifier (e.g., the Bates range) any portions of the ESI that should be treated as “CONFIDENTIAL–SUBJECTTOPROTECTIVEORDER,”andanyportionsoftheESI that should be treated as “ATTORNEYS’ EYES ONLY – SUBJECT TO PROTECTIVE ORDER.” c. Deposition Testimony. Deposition testimony will be deemed confidential only if designated as such when the deposition is taken or within _____ days after receipt of the deposition transcript. Such designation must indicate which Confidentiality Designation applies, and must be specific as to the portions of the transcript and/or any exhibitstowhichthatConfidentialityDesignationapplies,exceptthatanyexhibitthatwas markedwithaConfidentiality Designationat thetimeofproduction,andwhichstill bears that mark at the time of its use in a deposition, shall be presumed to fall within the
provisions ofthis Order without furtherdesignation. 6. LimitationOfUse. a. General Protections. All information that has received a Confidentiality Designation, including all information derived therefrom, shall be used by any Receiving Party solely forpurposes ofprosecuting ordefendingthis Action. AReceivingPartyshall not use or disclose the Confidential Information for any other purpose, including but not limited to any business, commercial, or competitive purpose. Except as set forth in this Order, a Receiving Party shall not disclose Confidential Information to any third party. This Order shall not prevent the Producing Entity from using or disclosing information it
has designated as Confidential Information, and that belongs to the Producing Entity, for any purpose that the Producing Entity deems appropriate, except that the Producing Entity’s voluntary disclosure of Confidential Information outside the scope of this Action may impact the protection that this Order would otherwise provide with regard to such information,oncedisclosed. b. Persons To Whom Information Marked “Confidential” May Be Disclosed. Use of any information, documents, or portions of documents marked “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” including all information derivedtherefrom,shallberestrictedsolelytothefollowingpersonswhoagreetobebound by the terms of this Protective Order, unless additional persons are stipulated by counsel orauthorizedbytheCourt: 1. outside counsel of record for the parties, and the administrative staff of outsidecounsel's firms; 2. in-house counsel for the parties, and the administrative staff for each in- housecounsel; 3. anyparty tothis actionwhois an individual; 4. as to any party to this action who is not an individual, every employee, director, officer, or manager of that party, but only to the extent necessary to furthertheinterest oftheparties in this litigation; 5. independent consultants or expert witnesses (including partners, associates and employees of the firm which employs such consultant or expert) retainedbyapartyoritsattorneysforpurposesofthislitigation,butonlyto the extent necessary to further the interest of the parties in this litigation, andonlyaftersuchpersonshavecompletedthecertificationattachedhereto asAttachmentA,AcknowledgmentofUnderstandingandAgreementtobe Bound; 6. the Court and its personnel, including, but not limited to, stenographic reporters regularly employed by the Court and stenographic reporters not regularlyemployedbytheCourtwhoareengagedbytheCourtortheparties during thelitigationofthis action; 7. theauthorsandtheoriginal recipientsofthedocuments; 8. anycourt reporterorvideographer reportingadeposition; 9. employeesofcopyservices,microfilmingordatabaseservices,trialsupport firms,and/ortranslatorswhoareengagedbythepartiesduringthelitigation ofthis action; 10. interviewees,potentialwitnesses,deponents,hearingortrialwitnesses,and any other person, where counsel for a party to this action in good faith determinestheindividual shouldbeprovidedaccess to suchinformationin orderforcounseltomoreeffectivelyprosecuteordefendthisaction(aslong as the disclosure occurs in the presence of counsel, and copies, duplicates, images,orthelikearenotremovedorretainedbyanyinterviewee,potential witness, deponent, or hearing or trial witness), provided, however, that in all such cases the individual to whom disclosure is to be made has been informed that the information contained in the disclosed document(s) is confidential and protected by Court Order, that the individual understands that he/she is prohibited from disclosing any information contained in the document(s)toanyone; or 11. anyotherpersonagreedtoin writingbytheparties. Prior to being shown any documents produced by another party marked “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” any person listed under paragraph 6(b)(3), 6(b)(4), or 6(b)(11) shall be advised that the confidential information is being disclosed pursuant to and subject totheterms ofthis ProtectiveOrder. c. Persons To Whom Information Marked “Attorneys’ Eyes Only” May Be Disclosed. Use of any information, documents, or portions of documents marked “ATTORNEYS’ EYES ONLY – SUBJECT TO PROTECTIVE ORDER,” including all informationderivedtherefrom,shallberestrictedsolelytothefollowingpersonswhoagree to be bound by the terms of this Protective Order, unless additional persons are stipulated bycounsel orauthorized bytheCourt: 1. outside counsel of record for the parties, and the administrative staff of outsidecounsel's firms; 2. onedesignatedrepresentativefrom in-house counsel fortheparties; 3. independent consultants or expert witnesses (including partners, associates and employees of the firm which employs such consultant or expert) retainedbyapartyoritsattorneysforpurposesofthislitigation,butonlyto the extent necessary to further the interest of the parties in this litigation, andonlyaftersuchpersonshavecompletedthecertificationattachedhereto asAttachmentA,AcknowledgmentofUnderstandingandAgreementtobe Bound; 4. the Court and its personnel, including, but not limited to, stenographic reporters regularly employed by the Court and stenographic reporters not regularlyemployedbytheCourtwhoareengagedbytheCourtortheparties during thelitigationofthis action; 5. theauthorsandtheoriginal recipientsofthedocuments; 6. anycourt reporterorvideographer reportingadeposition; 7. employeesofcopyservices,microfilmingordatabaseservices,trialsupport firms,and/ortranslatorswhoareengagedbythepartiesduringthelitigation ofthis action; 8. anyotherpersonagreedtoin writingbytheparties. Prior to being shown any documents produced by another party marked “ATTORNEYS’ EYES ONLY–SUBJECTTOPROTECTIVEORDER,”anypersonlistedunderparagraph6(c)(8)shall beadvisedthattheconfidentialinformationisbeingdisclosedpursuanttoandsubjecttotheterms ofthis ProtectiveOrder. 7. Inadvertent Production. Inadvertent production of any document or information withaConfidentialityDesignationshallbegovernedbyFed.R.Evid.502.Pursuanttosubsections (d) and (e) of that Rule, the parties agree to, and the Court orders, protection of Protected Information against claims of waiver (including as against third parties and in other Federal and State proceedings) in the event such information is produced during the course of the Litigation, whetherpursuanttoaCourtorder,aparties’discoveryrequest,orinformalproduction,asfollows:
a. the production of documents or electronically stored information (“ESI”) (including, without limitation, metadata) subject to a legally recognized claim of privilege or other protection from production or other disclosure (collectively, “ProtectedInformation”),includingwithoutlimitationtheattorney-clientprivilege and work-product doctrine, shall in no way constitute the voluntary disclosure of suchProtected Information; b. the production of Protected Information shall not result in the waiver of any privilege or protection associated with such Protected Information as to the receivingparty,oranythirdparties,andshallnotresultinanywaiverofprotection, includingsubject matterwaiver,of anykind; c. ifanydocumentorESI(including,withoutlimitation,metadata)receivedbyaparty is onits faceclearly subject to a legallyrecognizableprivilege,immunity, orother rightnottoproducesuchinformation,theReceivingPartywillpromptlynotifythe Producing Entity in writing that it has discovered Protected Information, identify the Protected Information by Bates Number range, and return or sequester such Protected Information until the Producing Entity confirms whether it does indeed assert any privilege protecting this information. Once the Producing Entity asserts privilege over such Protected Information (as described in Subparagraph (e) below), the Receiving Party will return, sequester, or destroy all copies of such Protected Information, along with any notes, abstracts or compilations of the content thereof,withinten(10)business days ofnoticefrom theProducing Entity; d. upon the request of the Producing Entity, the Receiving Party will promptly disclose the names of any individuals who have read or have had access to the Protected Information; e. iftheProducingEntityintendstoassertaclaimofprivilegeorotherprotectionover Protected Information identified by the receiving party, the Producing Entity will, within ten (10) business days of receiving the Receiving Party’s written notification, inform the Receiving Party of such intention in writing and shall provide the Receiving Party with a log for such Protected Information that is consistent with the requirements of the Federal Rules of Civil Procedure, setting forththebasisfortheclaimofprivilege,immunityorbasisfornon-disclosure,and intheevent,ifanyportionoftheProtectedInformationdoesnotcontainprivileged or protected information, the Producing Entity shall also provide to the Receiving Party a redacted copy of the Protected Information that omits the information that the Producing Entity believes is subject to a claim of privilege, immunity or other protection; f. if, during the course of the litigation, a party determines it has produced Protected Information, the Producing Entity may notify the Receiving Party of such production in writing. The Producing Entity’s written notice must identify the ProtectedInformationbyBatesNumberrange,theprivilegeorprotectionclaimed, andthebasisfortheassertionoftheprivilegeand shallprovidethereceivingparty with a log for such Protected Information that is consistent with the requirements of the Federal Rules of Civil Procedure, setting forth the basis for the claim of privilege,immunityorbasisfornon-disclosure,andintheevent anyportionofthe Protected Information does not contain privileged or protected information, the Producing Entity shall also provide to the receiving party a redacted copy of the ProtectedInformationthatomitstheinformationthattheProducingEntitybelieves is subject to a claim of privilege, immunity or other protection. The Producing Entity must also demand the return of the Protected Information. After receiving such written notification, the Receiving Party must, within ten (10) business days of receiving the written notification, return, sequester, or destroy the specified Protected Information and any copies, along with any notes, abstracts or compilations ofthecontent thereof; g. a Receiving Party’s return, sequestration, or destruction of such Protected Informationas providedin theSubparagraphs abovewill not act as awaiverofthe Receiving Party’s right to move for the production of the returned, sequestered, or destroyed Protected Information on grounds that the Protected Information is not in fact subject to a viable claim of privilege or other protection. However, the Receiving Party is prohibited and estopped from arguing that the Producing Entity’s production of the Protected Information in this matter acts as a waiver of applicableprivilegesorprotections,thatthedisclosureoftheProtectedInformation bytheProducingEntity wasnotinadvertent,that theProducingEntitydidnottake reasonable steps to prevent the disclosure of the Protected Information, or that the Producing Entity did nottakereasonablesteps to rectifysuchdisclosure; and h. nothing contained herein is intended to or shall limit a Producing Entity’s right to conductareviewofdocumentsorESI(including,withoutlimitation,metadata),for relevance, responsiveness, and/or the segregation of privileged and/or protected informationbeforesuchinformationis producedtotheReceivingParty; i. prior to production to another party, all copies, electronic images, duplicates, extracts, summaries, or descriptions (collectively “copies”) of documents marked withaConfidentialityDesignationunderthisOrder,orinanyindividualportionof such a document, shall be affixed with the same Confidentiality Designation if it does not already appear on the copy. All such copies shall thereafter be entitled to theprotectionofthisOrder.Theterm“copies”shallnotincludeindices,electronic databases,orlistsofdocumentsprovidedtheseindices,electronicdatabases,orlists do not contain substantial portions orimages of the text of confidential documents or otherwise disclose the substance of the confidential information contained in thosedocuments. 8. FilingMaterials ContainingInformation WithAConfidentialityDesignation. In the event a party seeks to file with the Court any confidential information subject to protection under this Order, that party must take appropriate action to ensure that the document receives proper protection from public disclosure, including: (a) filing a redacted document with the consent of the party who designated the document as confidential; (b) where appropriate (e.g., in relation to discovery and evidentiary motions), submitting the document solely for in camera review; or (c)when the preceding measures are inadequate, seeking permission to file the document underseal byfilingamotion forleaveto fileunderseal. AnymotiontofileadocumentsubjecttothisOrderundersealmustmeettheSixthCircuit’s standard set forth in Shane Group, Inc. v. Blue Cross Blue Shield of Michigan,
825 F.3d 299(6th Cir. 2016). The burden of demonstrating the need for and appropriateness of a sealing order is borne by the moving party, and requires the moving party to analyze in detail, document by document, the propriety of secrecy, providing reasons and legal citations. Regardless of whether the parties agree, it remains the Court’s independent obligation to determine whether a seal is appropriate for any given document or portion thereof. Any proposed sealing, even when compelling reasons exist, must benarrowlytailoredto servethecompelling reasons. When aparty to this Orderseeks to filedocuments whichit believes may warrant sealing,
but is not the party who may be prejudiced by the document or documents becoming part of the public record, the filing party shall provide the potentially-prejudiced party or parties, or any potentially-prejudiced third party or parties, with written notification of its intent to file such documents at least (14) fourteen days before doing so. After being provided such notice, the potentially harmed party or parties will then have (7) seven days to file with the Court a motion forsealing.TheCourt will ruleonthemotion as promptlyas possible. 9. Attorneys Allowed To Provide Advice. Nothing in this Order shall bar or otherwiserestrictanyattorneyforanypartyfromrenderingadvicetohisorherclientwithrespect to this case or from doing anything necessary to prosecute or defend this case and furthering the
interestsofhisorherclient,exceptforthedisclosureoftheConfidentialInformationasproscribed in thisOrder. 10. ExcludingOthersFromAccess. WheneverinformationbearingaConfidentiality DesignationpursuanttothisProtectiveOrderistobediscussedatadeposition,thepersonorentity that designated the information may exclude from the room any person, other than persons designatedin Paragraph 6ofthis Order,as appropriate,forthat portion ofthedeposition. 11. NoVoluntaryDisclosureToOtherEntities.Thepartiesoranyoneactingontheir behalf may not voluntarily disclose any Confidential Information to any state or federal law enforcementorregulatoryagency,oranyemployeethereof,exceptinthis litigationassetforthin Paragraph 6 of this Order or as otherwise commanded by law or provided in this Order. Nothing in this Order shall prevent a party from providing information in its possession in response to a valid order or subpoena from a law enforcement or regulatory agency requiring the production of such information, except that, prior to such production, the party producing the information shall provide as much advance notice as possible to the person or entity that designated the material as
confidential to facilitate that party’s efforts to preserve the confidentiality of the material, if warranted. 12. Disputes As To Designations. Each party has the right to dispute the Confidentiality Designation asserted by any other party or subpoenaed person or entity in accordance with this Protective Order. If a party believes that any documents or materials have beeninappropriatelydesignatedbyanotherpartyorsubpoenaedparty,thatpartyshallconferwith counsel for the person or entity that designated the documents or materials. As part of that conferral, the designating person or entity must assess whether redaction is a viable alternative to completenon-disclosure.IfanypartychallengestheConfidentialityDesignationofanydocument
orinformation,theburdentoproperly maintainthedesignationshall,atall times,remainwiththe person or entity that made the designation to show that said document or information should remain protected pursuant to Federal Civil Rule 26(c). In the event of disagreement, then the designating person or entity shall file a motion pursuant to Federal Civil Rule 26(c). A party who disagrees with the designation must nevertheless abide by that designation until the matter is resolvedbyagreementof theparties orbyorderof theCourt. 13. Information Security Protections. Any person in possession of Confidential Information received from another person or entity in connection with this Action shall maintain an information security program that includes reasonable administrative, technical, and physical safeguards designed to protect the security and confidentiality of such Confidential Information, protect against any reasonably anticipated threats or hazards to the security of such Confidential Information,andprotect against unauthorized access to oruseofsuchConfidential Information. If a Receiving Party discovers a breach of security, including any actual or suspected unauthorized access, to Confidential Information subject to this Order, they shall: (1) notify the
person or entity who designated the materials under the terms of this Orderof such breach; (2)investigate and take reasonable efforts to remediate the effects of the breach; and (3)provide sufficientinformationaboutthebreachthattheProducingEntitycanreasonablyascertainthesize andscopeofthebreach.TheReceivingPartyagreestocooperatewiththeProducingEntityorlaw enforcement in investigating any such security incident. In any event, the Receiving Party shall promptlytakeallnecessaryandappropriatecorrectiveactiontoterminatetheunauthorizedaccess. 14. All Trials Open To Public. All trials, and certain pretrial proceedings and hearings, are open to the publ-ic-(collectively a “Public Hearing” or “Public Hearings”). Absent further order of the Court, there will be no restrictions on any Party’s ability to the use during a
Public Hearing any document or information that has marked with a Confidentiality Designation ordocumentsorinformationderivedtherefromthatwoulddisclosesuchconfidentialinformation. However, if a party intends to present at a Public Hearing any document or information that has been so designated, the party intending to present such document or information shall provide advance notice to the person or entity that made the Confidentiality Designation at least (5) five daysbeforethePublicHearingbyidentifyingthedocumentsorinformationatissueasspecifically as possible (i.e., by Bates Number, page range, deposition transcript line, etc.) without divulging theactualdocuments or information. Anyperson maythenseekappropriaterelieffrom theCourt regarding restrictions on the use of such documents or information at trial, or sealing of the courtroom, ifappropriate. 15. No Waiver Of Right To Object. This Order does not limit the right of any party to object to thescopeof discoveryin theabove-captionedaction. 16. No Determination Of Admissibility. This Order does not constitute a
determination of the admissibilityorevidentiaryfoundationfor thedocuments or awaiver of any party’sobjections thereto. 17. NoAdmissions.Designationbyeitherpartyofinformationordocumentsunderthe terms ofthis Order,orfailureto so designate,will not constituteanadmissionthat informationor documents are or are not confidential or trade secrets. Neither party may introduce into evidence in any proceeding between the parties, other than a motion to determine whether the Protective Order covers the information or documents in dispute, the fact that the other party designated or failedto designateinformation ordocuments underthis Order. 18. No Prior Judicial Determination. This Order is based on the representations and
agreements of the parties and is entered for the purpose of facilitating discovery in this action. Nothing in this Order shall be construed or presented as a judicial determination that any documents or information as to which counsel or the parties made a Confidentiality Designation is in fact subject to protection under Rule 26(c) of the Federal Rules of Civil Procedure or otherwiseuntil suchtimeastheCourt mayruleon aspecificdocument orissue. 19. Order Subject To Modification. This Order shall be subject to modification by theCourtonitsownmotionoronmotionofapartyoranyotherpersonwithstandingconcerning thesubject matter. 20. PartiesMayConsentToDisclosure.Nothingshallpreventdisclosurebeyondthe terms of this Order if all parties consent to such disclosure, or if the Court, after notice to all affected parties, permits such disclosure. Specifically, if and to the extent any party wishes to disclose any Confidential Information beyond the terms of this Order, that party shall provide all other parties with reasonable notice in writing of its request to so disclose the materials. If the
parties cannot resolve their disagreement with respect to the disclosure of any Confidential Information, then a party may petition the Court for a determination of these issues. In addition, any interested member of the public may also challenge the designation of any material as confidential, pursuant to theterms ofthis paragraph. 21. ReturnOfMaterialsUponTerminationOfLitigation.Uponthewrittenrequest and expense of the Producing Entity, within 30 days after the entry of a final judgment no longer subject toappeal onthemerits ofthis case,ortheexecutionofanyagreement betweentheparties to resolve amicably and settle this case, the parties and any person authorized by this Protective Order to receive confidential information shall return to the Producing Entity, or destroy, all
information and documents subject to this Protective Order, unless the specific document or information has been offered into evidence or filed without restriction as to disclosure. The party requesting the return of materials shall pay the reasonable costs of responding to its request. The party returning or destroying the documents or other information shall certify that it has not maintainedanycopies of confidential information,except as permittedbythis Order. 22. Counsel Allowed To Retain Copy Of Filings. Nothing in this Protective Order shall prevent outside counsel for a party from maintaining in its files a copy of any filings in the Action, including any such filings that incorporate or attach Confidential Information. Moreover, an attorney may use his or her work product in subsequent litigation provided that such use does not disclose any Confidential Information.
SO ORDERED.
US. District Judge/U.S. Magistrat@¥udge
AGREED TO: /s/ Elizabeth S. Tuck /s/ Rachel Tom-Quinn Elizabeth S. Tuck (#0076542) John E. Joseph (OH Bar No. 74445) The Tuck Firm, LLC HOLLAND & KNIGHT LLP 810 Sycamore Street, Fourth Floor 1650 Market Street, Suite 3300 Cincinnati, OH 45202 Philadelphia, PA 19103 (513) 545-6781 Telephone: (615) 244-6380 (513) 263-9081 Fax Facsimile: (615) 244-6804 Email: [email protected] [email protected] Counsel for Plaintiff Mark W. Peters (TN Bar No. 018422) (Pro Hac Vice) Rachel Tom-Quinn (TN Bar No. 039559) (Pro Hac Vice) Nashville City Center 511 Union Street, Suite 2700 Nashville, Tennessee 37219-8966 [email protected] Rachel. [email protected] Attorneys for Defendants
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UNITEDSTATES DISTRICTCOURT SOUTHERNDISTRICTOFOHIO WESTERNDIVISION NICOLEFINLEY, : : Plaintiff(s), : CaseNo.1-22-cv-00720 : Judge: MatthewW. McFarland v. : MagistrateJudge: Karen L.Litkovitz : SEVENHILLS OB-GYNASSOCIATES, : LLC : Defendant(s). : : FORMPROTECTIVE ORDER ATTACHMENT A The undersigned hereby acknowledges that [he/she] has read the Protective Order dated [INSERTDATE]intheabove-captionedactionandattachedhereto,understandsthetermsthereof, and agrees to be bound by its terms. The undersigned submits to the jurisdiction of the United States District Court for the Southern District of Ohio in matters relating to the Protective Order and understands that the terms of the Protective Order obligate [him/her] to use documents designated “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” or “ATTORNEYS’ EYE ONLY – SUBJECT TO PROTECTIVE ORDER” in accordance with the Order, solely for thepurposeoftheabove-captionedaction,andnot todiscloseanysuchdocumentsorinformation deriveddirectlytherefrom to anyotherperson, firm, orconcern. The undersigned acknowledges that violation of the Protective Order may result in penaltiesforcontempt of court. Name: Job Title: Employer:
Business Address:
Date: Signature
Reference
- Status
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