Zimmerman v. DJGN LLC et al

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION - CINCINNATI
BRANDON ZIMMERMAN, 	Case No. l:25-cv-729
Plaintiff, 	Judge Matthew W. McFarland
V.
DJGN, LLC, et al.,
Defendants.
STIPULATED PROTECTIVE ORDER
This matter is before the Court on the parties' Joint Request for a Protective Order
(Doc. 23). Pursuant to the parties' joint request that the Court enter this Order, and their
agreement that the following limitations and restrictions should apply to documents and
information produced for inspection and copying during the course of this litigation (the
"Action"), for good cause shown, the Court hereby ORDERS that:
1. 	Scope. 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,
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including all copies, excerpts, and summaries thereof (collectively the "Confidential
Information").
2. 	Purpose. The purpose of this Protective Order is to protect against the unnecessary
disclosure of Confidential 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 which contain or refer to the Confidential Information
or information contained therein.
4. 	Designating 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 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
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document or other material has any status or protection by statute or otherwise except to
the extent and for the purposes of this Order.
5. 	Form and Timing Of Designation.
a. 	Documents 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. Such materials shall be designated as confidential 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 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."
c. 	Deposition Testimony. Deposition testimony will be deemed confidential
only if designated as such when the deposition is taken or within fourteen (14)
days after receipt of the deposition transcript. Such designation must be specific
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as to the portions of the transcript and/ or any exhibits to be protected, except that
any exhibit that has previously been marked as "CONFIDENTIAL - SUBJECT TO
PROTECTIVE ORDER" at the time of production, and which still bears that mark
at the time of its use in a deposition, shall be presumed to be confidential under
this Order without further designation.
6. 	Limitation Of Use.
a. 	General 	Protections. 	All 	information 	designated 	"Confidential" 	and
subject to this Protective Order, including all information derived therefrom, shall
be used by the Receiving Party solely for purposes of prosecuting or defending
this 	Action. The Receiving Party shall 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, the
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, once disclosed.
b. 	Persons To Whom Confidential Information May Be Disclosed. Use of
any information, documents, or portions of documents marked "CONFIDENTIAL
- 	SUBJECT 	TO 	PROTECTIVE 	ORDER," 	including 	all 	information 	derived
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therefrom, shall be restricted solely to the following persons who agree to be
bound by the terms of this Protective Order, unless additional persons are
stipulated by counsel or authorized by the Court:
1. 	outside counsel of record for the parties, and the administrative staff
of outside counsel's firms;
2. 	in-house counsel for the parties, and the administrative staff for each
in-house counsel;
3. 	any party to this action who is an individual, including any named
or opt-in plaintiffs;
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 further the interest of the parties in this litigation;
5. 	independent consultants or expert witnesses (including partners,
associates and employees of the company or firm which employs
such consultant or expert) retained by a party or its attorneys for
purposes of this litigation, but only to the extent necessary to further
the interest of the parties in this litigation, and only after such
persons 	have 	completed 	the 	certification 	attached 	hereto 	as
Attachment A, Acknowledgment of Understanding and Agreement
to be Bound;
6. 	the 	Court 	and 	its 	personnel, 	including, 	but 	not 	limited 	to,
stenographic reporters and videographers regularly employed by
the 	Court 	and 	stenographic 	reporters 	and 	videographers 	not
regularly employed by the Court who are engaged by the Court or
the parties during the litigation of this action;
7. 	the authors and the original recipients of the documents;
8. 	any court reporter or videographer reporting a deposition;
9. 	employees of copy services, microfilming or database services, trial
support firms, and/ or translators who are engaged by the parties
during the litigation of this action;
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10. 	interviewees, 	potential 	witnesses, 	deponents, 	hearing 	or 	trial
witnesses, and any other person, where counsel for a party to this
action in good faith determines the individual should be provided
access to such information in order for counsel to more effectively
prosecute or defend this action (as long as the disclosure occurs in
the presence of counsel, and copies, duplicates, images, or the like
are not removed or retained by any interviewee, 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) to anyone; or
11. 	any other person agreed to in writing by the parties.
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 to the terms of this Protective Order.
7. 	Inadvertent Production. Inadvertent production of any document or information
with the designation of "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" shall
be governed by Federal Rule of Evidence 502. Pursuant to subsections (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, whether pursuant to a Court order, a parties' discovery request, or informal
production, as follows:
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
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(collectively, 	"Protected 	Information"), 	including without limitation the
attorney-client 	privilege 	and 	work-product 	doctrine, 	shall 	in 	no 	way
constitute the voluntary disclosure of such Protected 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
receiving party, or any third parties, and shall not result in any waiver of
protection, including subject matter waiver, of any kind;
c. 	if any document or ESI (including, without limitation, metadata) received by
a party is on its face clearly subject to a legally recognizable privilege,
immunity, or other right not to produce such information, the Receiving
Party will promptly notify the 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, within ten (10) business days of notice from the
Producing 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. 	if the Producing Entity intends to assert a claim of privilege or other
protection over 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 forth the basis for the claim of privilege,
immunity or basis for non-disclosure, and in the event, if any portion of the
Protected Information does not contain privileged 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
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of such production in writing. The Producing Entity's written notice must
identify the Protected Information by Bates Number range, the privilege or
protection claimed, and the basis for the assertion of the privilege 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 forth the basis for the claim of privilege, immunity or basis for non-
disclosure, and in the event any portion of the Protected Information does
not contain privileged 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. 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 of the content thereof;
g. 	a Receiving Party's return, sequestration, or destruction of such Protected
Information as provided in the Subparagraphs above will not act as a waiver
of the 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 applicable privileges or
protections, that the disclosure of the Protected Information by the Producing
Entity was not inadvertent, that the Producing Entity did not take reasonable
steps to prevent the disclosure of the Protected Information, or that the
Producing Entity did not take reasonable steps to rectify such disclosure;
h. 	nothing contained herein is intended to or shall limit a Producing Entity's
right to conduct a review of documents or ESI (including, without limitation,
metadata), 	for 	relevance, 	responsiveness, 	and/ or 	the 	segregation 	of
privileged 	and/ or 	protected 	information 	before 	such 	information 	is
produced to the Receiving Party; and
i. 	prior to production to another party, all copies, electronic images, duplicates,
extracts, summaries, or descriptions (collectively "copies") of documents
marked "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" under
this Order, or in any individual portion of such a document, shall be affixed
with 	the 	designation 	"CONFIDENTIAL 	- 	SUBJECT 	TO 	PROTECTIVE
ORDER" if it does not already appear on the copy. All such copies shall
thereafter be entitled to the protection of this Order. The term "copies" shall
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not include indices, electronic databases, or lists of documents provided these
indices, electronic databases, or lists do not contain substantial portions or
images of the text of confidential documents or otherwise disclose the
substance of the confidential information contained in those documents.
8. 	Filing Materials Containing Information Designated Confidential. In the event
a party seeks to file with the Court any information marked "CONFIDENTIAL -
SUBJECT TO PROTECTIVE ORDER" subject to protection under this Order, the party
seeking to file such information 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 under seal by filing a motion for
leave to file under seal (unless the party seeking to file the designated information is not
the designating party).
Any motion to file a document subject to this Order under seal must meet the Sixth
Circuit'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
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thereof. Any proposed sealing, even when compelling reasons exist, must be narrowly
tailored to serve the compelling reasons.
When a party to this Order seeks to file documents which another party has
designated as confidential, 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 (or as soon as practicable)
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 for sealing. The Court will
rule on the motion as promptly as possible. If no such motion is filed by this deadline,
then the information shall not be covered by this Order. If the Court has not adjudicated
such motion by a deadline for when the non-moving party must file another motion or
otherwise seek relief from this Court, then the information submitted under seal may be
referenced by citation in other briefing.
9. 	Attorneys Allowed To Provide Advice. Nothing in this Order shall bar or
otherwise restrict any attorney for any party from rendering advice to his or her client
with respect to this case or from doing anything necessary to prosecute or defend this
case and furthering the interests of his or her client, except for the disclosure of the
Confidential Information as proscribed in this Order.
10. 	Excluding 	Others 	From 	Access. 	Whenever 	information 	designated 	as
"Confidential" pursuant to this Protective Order is to be discussed at a deposition, the
person or entity that designated the information as "Confidential" may exclude from the
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room any person, other than persons designated in Paragraph 6 of this Order, as
appropriate, for that portion of the deposition.
11. 	No Voluntary Disclosure To Other Entities. The parties or anyone acting on their
behalf may not voluntarily disclose any Confidential Information to any state or federal
law enforcement or regulatory agency, or any employee thereof, except in this litigation
as set forth in 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 confidential
status claimed 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 been
inappropriately designated by another party or subpoenaed party, that party shall confer
with 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 	complete 	non-disclosure. 	If 	any 	party 	challenges 	the
"CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" designation of any document
or information, the burden to properly maintain the designation shall, at all times, remain
with the person or entity that made the designation to show that said document or
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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 resolved by agreement of the parties or by
order of the Court.
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, 	and 	protect 	against
unauthorized access to or use of such Confidential Information.
If the 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 as confidential of such
breach; (2) investigate and take reasonable efforts to remediate the effects of the breach;
and (3) provide sufficient information about the breach that the Producing Entity can
reasonably ascertain the size and scope of the breach. The Receiving Party agrees to
cooperate with the Producing Entity or law enforcement in investigating any such
security incident. In any event, the Receiving Party shall promptly take all necessary and
appropriate corrective action to terminate the unauthorized access.
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14. 	All Trials Open To Public. 	All trials, and certain pretrial proceedings and
hearings, are open to the public (collectively a "Public Hearing" or "Public Hearings").
Absent further order of the Court, there will be no restrictions on any Party's ability to
use during a Public Hearing any document or information that has been designated as
"CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER," or documents or information
derived therefrom that would disclose such confidential information. 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 designated the material as Confidential at least
(5) five days before the Public Hearing by identifying the documents or information at
issue as specifically as possible (i.e., by Bates Number, page range, deposition transcript
line, etc.) without divulging the actual documents or information. Any person may then
seek appropriate relief from 	the Court regarding restrictions 	on the 	use of such
documents or information at trial, or sealing of the courtroom, if appropriate.
15. 	No Waiver Of Right To Object. This Order does not limit the right of any party
to object to the scope of discovery in the above-captioned action.
16. 	No 	Determination 	Of 	Admissibility. 	This 	Order 	does 	not 	constitute 	a
determination of the admissibility or evidentiary foundation for the documents or a
waiver of any party's objections thereto.
17. 	No Admissions. Designation by either party of information or documents as
"CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER," or failure to so designate, will
not constitute an admission that information or documents are or are not confidential or
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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 failed to
designate information or documents as "CONFIDENTIAL-SUBJECT TO PROTECTIVE
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 designated as "CONFIDENTIAL - SUBJECT TO
PROTECTIVE ORDER" by counsel or the parties is in fact subject to protection under
Rule 26(c) of the Federal Rules of Civil Procedure or otherwise until such time as the
Court may rule on a specific document or issue.
19. 	Order Subject To Modification. This Order shall be subject to modification by the
Court sua sponte or on motion of a party or any other person with standing concerning
the subject matter.
20. 	Parties May Consent To Disclosure. Nothing shall prevent disclosure beyond the
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
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
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determination of these issues. In addition, any interested member of the public may also
challenge the designation of any material as confidential, pursuant to the terms of this
paragraph.
21. 	Return Of Materials Upon Termination Of Litigation. Upon the written request
and expense of the Producing Entity, within 30 days after the entry of a final judgment
no longer subject to appeal on the merits of this case, or the execution of any agreement
between the parties 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 maintained any copies of
confidential information, except as permitted by this 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 	information
designated as "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER." Moreover, an
attorney may use his or her work product in subsequent litigation provided that such use
does 	not 	disclose 	any 	information 	or 	documents 	designated 	in 	this 	matter 	as
"CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER."
IT IS SO ORDERED.
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
By: <JWtk-w:<M~ ~JUDGE MATTHEW W. McARLAND
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IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION - CINCINNATI
BRANDON ZIMMERMAN, 	Case No. 1:25-cv-729
V .
DJGN, LLC, et al.,
Plaintiff, 	Judge Matthew W. McFarland
Defendants.
STIPULATED PROTECTIVE ORDER
ATTACHMENT A
The undersigned hereby acknowledges that [he/she] has read the Protective
Order in the above-captioned action and attached hereto, understands the terms thereof,
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" in accordance with the Order, solely for the purpose of the above-captioned
action, and not to disclose any such documents or information derived directly therefrom
to any other person, firm, or concern.
The undersigned acknowledges that violation of the Protective Order may result
in penalties for contempt of court.
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Name:
Job Title:
Employer:
Business Address: -------------------
Date:
Signature:
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