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It limits use of confidential materials to prosecuting or defending the action, restricts disclosure to bound persons, and clarifies confidentiality protections and limitations regarding publicly available 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limitations and restrictions should apply to documents and information produced for inspection and copying during the course of this litigation (the “Action”), the Court hereby ORDERS that:\n1.\tScope. This Protective Order (hereinafter “Protective Order” or “Order”) shall apply to all documents or other information produced in the course of discovery in this Action that the producing person or entity (the “Producing Entity”) has designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” 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”).\n2.\tPurpose. The purpose of this Protective Order is to protect against the unnecessary disclosure of Confidential Information.\n3.\tDisclosure 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 which contain or refer to the Confidential Information or information contained therein.\n4.\tDesignating Material As Confidential. Any party, or any third party subpoenaed by one of the parties, may designate as confidential and subject to this Protective Order any documents, testimony, written responses, or other materials produced 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. Information that is publicly available may not be designated as confidential. The designation of materials as confidential pursuant to the terms of this Protective Order does not mean that the document or other material has any status or protection by statute or otherwise except to the extent and for the purposes of this Order.\n5.\tForm and Timing Of Designation.\na.\tDocuments And Written Materials. The Producing Entity shall designate any document or other written materials as confidential pursuant to this Order by marking each page of the material with a stamp identifying it as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” 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.\nb.\tElectronically Stored Information (“ESI”): If a production response includes ESI, the Producing Entity shall make an effort to include within the electronic files themselves the designation “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER” 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 – SUBJECT TO PROTECTIVE ORDER.”\nc.\tDeposi","cbCaim56w7MU0hoo","https://ap.wps.com/l/cbCaim56w7MU0hoo","docx",48665,"English","# Scope\n## Purpose\n## Disclosure Defined\n## Designating Material As Confidential\n# Form and Timing Of Designation\n## Documents And Written Materials\n## Electronically Stored Information (ESI)\n## Deposition Testimony\n# Limitation Of Use\n## General Protections\n## Persons To Whom Confidential Information May Be Disclosed","[{\"question\":\"What types of materials qualify as “Confidential Information” under this order?\",\"answer\":\"Confidential Information includes documents and other information produced during discovery that are designated as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” including initial disclosures, discovery responses, deposition testimony and exhibits, and subpoena responses by non-parties, along with copies, excerpts, and summaries.\"},{\"question\":\"How must documents be designated as confidential?\",\"answer\":\"The producing entity designates documents by marking each page with a stamp identifying it as “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” when practical, and doing so prior to or at the time of production or disclosure.\"},{\"question\":\"What limits apply to using and disclosing confidential materials?\",\"answer\":\"Confidential materials may be used only for prosecuting or defending the action, not for business, commercial, or competitive purposes, and disclosure to third parties is prohibited except as permitted by the order to persons who agree to be bound.\"}]","STIPULATED PROTECTIVE ORDER - UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO | DOCX",6]