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Hagopian v. Joseph

United States District Court, S.D. Illinois

January 2, 2018

BRANDON PATRICK HAGOPIAN, Plaintiff,
v.
CAPTAIN DAVID JOSEPH, JOHN LAKIN, C/O KYLE SHREIBER, C/O NICK, C/O JODY COLLMAN, DR. BLANKENSHIP, CAPTAIN GARY BOST, NURSE MAJOR, NURSE RUSHING, Defendants.

          PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION

          DONALD G. WILKERSON UNITED STATES MAGISTRATE JUDGE.

         Now pending before the Court is the Join Motion for Protective Order (Doc 80). Good cause having been shown, the motion is GRANTED.

         1. The Intent of the Parties: The parties wish to exchange documents that contain confidential and private information, including non-party pretrial detainee information and jail security information in the course of this lawsuit without frequent resort to the Court.

         2. Use of Material for Use in Action Only: This Stipulation and Order shall govern the production, use and handling of all documents and testimony, including without limitation interrogatory answers, responses to requests for production of documents, responses to requests for admissions, affidavits or other filings, briefs, memoranda of law, summaries, exhibits, transcripts, recordings, excerpts and notes prepared for, derived from, referring to or incorporating information contained in any of these materials (collectively, the “Material”) produced during discovery or any other phase of this action. All Material produced in the course of this action shall be used by the receiving party solely for the purpose of this action and there shall be no use of Material by the receiving party for any other purpose whatsoever.

         3. Designation of “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only” Material: Each party shall have the right to designate (such designation to be a “Designation” or such action to “Designate”) Material it produces which, in good faith, it believes to be confidential or proprietary information, as “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only” (“Confidential Information”), including but not limited to non-party pretrial detainee information and jail security information.

         4. Definitions of “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only” Material: The disclosing party must specify that any Confidential Information is either “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only.” The Confidential Information shall be handled according to such specification as described below. Confidential Information preferably will be Designated by stamping it with the appropriate legend, either “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only” at the time of its production. However, counsel may Designate Confidential Information as follows:

a. If Designated orally or by any other means at or before the time of production, the Designation must be confirmed within twenty (20) business days after the time of production in a writing identifying the Confidential Information by a number or other clear identifier and offering to stamp the legend thereon at a mutually agreed time or to otherwise affix the legend in a mutually agreed manner.
b. Any Designation of deposition testimony preferably should be made at the time of the giving of the testimony, but no later than twenty-one (21) days after receipt of the transcript by the Designating party. If made at the time of giving of the testimony, the reporter shall separately transcribe the Designated testimony and mark the face of each separate transcript accordingly. Testimony about any previously Designated Material shall be deemed to be so without further Designation. If a post-deposition Designation is made, the party making the later Designation shall be responsible for advising the reporter and all parties of the Designation and arranging for the return of all transcripts to the reporter for correction. The reporter shall certify that the corrected transcript is in all respects the same as the original except for the revised Designation. All expenses associated with the reporter's belated Designation efforts shall be borne by the party making the belated Designation.
c. At any deposition session, where appropriate, counsel for a party may temporarily Designate (“Temporary Designation”) as “CONFIDENTIAL” or “CONFIDENTIAL - Attorneys' Eyes Only” the entire deposition transcript and all information contained therein. Thereafter, any transcript and/or information subject to a Temporary Designation shall be deemed as required by such designation “CONFIDENTIAL” or “CONFIDENTIAL -Attorneys' Eyes Only” until twenty-one (21) days after receipt of a copy of the transcript by the Designating party. During that period, the party desiring to maintain confidentiality must Designate in writing those portions of the transcript, and only those portions will thereafter be handled and marked in accordance with the provisions of this Stipulated Protective Order. The party making the Temporary Designation shall be responsible for advising the reporter and all parties of any Designations and arranging for the return of all transcripts to the reporter for correction. The reporter shall certify that the corrected transcript is in all respects the same as the original except for the revised Designations. All expenses associated with the reporter's belated Designation efforts shall be borne by the party making the belated Designation.

         5. Disclosures of Confidential Material: Confidential Information which has been Designated by the disclosing party as “CONFIDENTIAL” shall not be disclosed or made available by the receiving party to any person other than:

a. The Court in this action and personnel thereof, as well as jurors;
b. The receiving party's litigation counsel of record, and clerical, paralegal and secretarial staff employed by such litigation counsel who are engaged in assisting such attorneys in the prosecution or defense of this action;
c. Court reporters during the course of depositions;
d. Testifying and non-testifying experts and any non-technical trial consultants; e. Any mediator agreed ...

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