PAGE 1 - STIPULATED PROTECTIVE ORDER 

4031623v2 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

SCORECARDS UNLIMITED, LLC 

Plaintiff, 

v. 

GOLF SCORECARDS, INC. 

Defendant. 

Civil Action No. 2:11cv 906 

STIPULATED PROTECTIVE 

ORDER 

Judge Algenon L. Marbley 

Magistrate Judge Mark R. Abel

STIPULATED PROTECTIVE ORDER 

The Court recognizes that disclosure and discovery activity are likely to arise that will 

require the disclosure of trade secrets, confidential research, development, manufacturing, 

financial, process, marketing, and business information, or other commercial information subject 

to Federal Rule of Civil Procedure 26(c). 

Good cause exists to protect this information from public disclosure. In the absence of a 

suitable protective order safeguarding the confidentiality of such information, the parties would 

be hampered in their ability to produce such information. 

Accordingly, the Court ORDERS that the parties shall adhere to the following: 

1. DESIGNATION OF PROTECTED MATERIAL 

1.1. This Order shall govern all documents and other products of discovery obtained 

by the parties from one another, and from third parties, all information copied or derived 

therefrom, as well as all copies, excerpts, summaries or compilations thereof, including 

documents produced pursuant to requests authorized by the Federal Rules of Civil Procedure, 

answers to interrogatories, deposition transcripts, responses to requests for admission, affidavits, 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 1 of 15 PAGEID #: <pageID>
PAGE 2 - STIPULATED PROTECTIVE ORDER 

4031623v2 

declarations, expert reports, and other such material and information as may be produced during 

the course of this litigation. 

1.2. In connection with discovery proceedings in this action, any party or third party 

may designate any non-public document, material, or information as "CONFIDENTIAL" or 

"HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY" (collectively referred to as 

"Protected Material"). 

(a) A party or third-party may designate as "CONFIDENTIAL" any 

information, document, or thing that the party or third-party reasonably and in good faith 

believes to contain confidential information subject to Fed. R. Civ. P. 26(c) used by it in, or 

pertaining to, its business and that is not generally known, and which that party or third-party 

would not normally reveal to third parties or, if disclosed, would require such third parties to 

maintain in confidence; 

(b) A party or third-party may designate as "HIGHLY CONFIDENTIAL – 

ATTORNEY EYES ONLY" such materials as the party or third-party reasonably and in good 

faith believes to contain particularly sensitive technical or business information relating to 

research for and production of current products; technical, business, and research information 

regarding future products; non-public and highly sensitive financial information; marketing and 

sales information, such as marketing plans and forecasts, customer lists, pricing data, cost data, 

customer orders, and customer quotations; any pending or abandoned patent applications, foreign 

or domestic; and such other documents, information, or materials that relate to other proprietary 

information that the designating party or third-party reasonably believes is of such nature and 

character that disclosure of such information would be harmful to the designating party or thirdparty. 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 2 of 15 PAGEID #: <pageID>
PAGE 3 - STIPULATED PROTECTIVE ORDER 

4031623v2 

1.3. The following information shall not be designated or protected under this 

Protective Order: 

(a) Information that is in the public domain at the time of disclosure, 

including patent file histories, publicly available prior art publications, catalogs and other 

advertising materials, press releases, and publicly-filed financial statements; 

(b) Information that at any time is made public through no act of a 

nondesignating party or any person or entity under a duty to preserve or maintain the 

confidentiality of the information; 

(c) Information that the designating party has not undertaken with others to 

maintain in confidence and that is in the possession of or becomes available to the receiving 

party other than through discovery in this action, but only if the receiving party can show by 

written documentation that the information independently came into its rightful possession; or 

(d) Information that is independently developed by the receiving party, as 

reflected by written documentation demonstrated to be in existence prior to production by the 

party claiming confidentiality. 

1.4. Any documents or things produced pursuant to a discovery request or other 

written materials exchanged by the parties (including discovery responses, letters, and briefs) 

that a party desires to designate as Protected Material shall be so designated by marking each 

page of the document, paper or thing CONFIDENTIAL or HIGHLY CONFIDENTIAL – 

ATTORNEY EYES ONLY, as appropriate, and indicating the identity of the producing party 

(e.g., through the use of an identifying prefix to the document identification (Bates) number). 

HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY designations made pursuant to this 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 3 of 15 PAGEID #: <pageID>
PAGE 4 - STIPULATED PROTECTIVE ORDER 

4031623v2 

Stipulated Protective Order may also be made by an abbreviated designation of "ATTORNEY 

EYES ONLY." 

1.5. In the event a party may make available certain of its files for inspection by 

another party, which files may contain non-confidential material as well as material that may be 

subject to protection under this Protective Order, with the intent that following such inspection 

the inspecting party will designate certain of the inspected documents to be copied and furnished 

to it, such files need not be marked with either confidentiality designation in advance, but shall 

all be treated as HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY materials. Only 

those persons identified in paragraph 2.2 below as permitted to view HIGHLY 

CONFIDENTIAL – ATTORNEY EYES ONLY materials may be present at any such 

inspection. When the producing party copies the documents to furnish to the inspecting party, 

the producing party shall mark Protected Material with the appropriate confidentiality 

designation to the extent warranted under paragraph 1.2. 

1.6. Whenever a deposition involves a disclosure of Protected Material, the following 

procedures shall apply: 

(a) Any party may designate any portion or all of a deposition as 

CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY by notifying the 

other parties on the record during the deposition. The Court Reporter shall be asked to make the 

appropriate confidentiality designation on each page of the transcript that contains 

CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY information. At 

that time, all persons not qualified to receive that category of information shall leave the room 

prior to continuation of the deposition and until the conclusion of such designated testimony; and 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 4 of 15 PAGEID #: <pageID>
PAGE 5 - STIPULATED PROTECTIVE ORDER 

4031623v2 

(b) Any party may also designate any portion or all of a deposition as 

CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY by notifying the 

other parties separately in writing within thirty days of receipt of the transcript. In such event, 

the parties shall confer as to the most convenient way to segregate the designated portions of the 

transcript. All information disclosed at a deposition and all information contained in deposition 

transcripts shall be treated as HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY for a 

period of thirty days after the receipt of the transcript to permit adequate time for review of the 

transcript and notice to other counsel regarding any designation as Protected Material by a 

designating party. 

2. ACCESS TO AND USE OF PROTECTED MATERIAL 

2.1. Protected Material, and all summaries, compilations, and derivations thereof, 

whether oral or written, shall be maintained in confidence, shall be used solely in the preparation, 

prosecution, or trial of this action and not for any other purpose, and shall be disclosed only as 

provided in the following paragraphs. 

Information which has been designated as HIGHLY CONFIDENTIAL – ATTORNEY 

EYES ONLY may be disclosed only to: 

(a) The outside attorneys and employees and contract personnel of such 

attorneys' firms who are actively engaged in assisting in this action; 

(b) The in-house counsel of a receiving party to whom disclosure is 

reasonably necessary for this litigation and who have signed the "Agreement to Be Bound by 

Protective Order" in Exhibit A; 

(c) Independent consultants or experts retained by the party or its attorneys in 

connection with this action, including technical experts, damage and industry experts, and jury or 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 5 of 15 PAGEID #: <pageID>
PAGE 6 - STIPULATED PROTECTIVE ORDER 

4031623v2 

trial consultants, together with their employees engaged in assisting in this action (including 

mock jurors), but only subject to the provisions of paragraph 2.3 below; 

(d) The Court and its personnel; 

(e) Court reporters and their personnel engaged in proceedings incident to 

preparation for trial or engaged in trial; 

(f) Professional vendors and their employees, including copy services, 

electronic discovery vendors, trial graphics services, and translation services, engaged by 

counsel; and 

(g) Any person who is indicated on the face of a document to have been an 

author, addressee, or copy recipient of the document, or the original source of the information. 

(h) Any person other than those identified in subsections (a)-(g) herein only 

by written consent of the producing party or upon order of the Court and on such conditions as 

may be agreed or ordered. 

2.2. Information that has been designated as CONFIDENTIAL may be disclosed only 

to: 

(a) The persons identified in paragraph 2.1; and 

(b) Any employee of a party, to whom disclosure is reasonably necessary for 

this litigant and litigation. 

2.3. Protected Material shall be disclosed to independent consultants and experts only 

upon the following terms: 

(a) Prior to any disclosure, an independent consultant or expert who has 

previously been employed or engaged by a party shall be identified in writing to the other parties' 

counsel by name, address, and corporate, business or other professional affiliation or 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 6 of 15 PAGEID #: <pageID>
PAGE 7 - STIPULATED PROTECTIVE ORDER 

4031623v2 

employment, together with a copy of the expert's curriculum vitae and a list of the expert's or 

consultant's litigation or consulting engagements for the past three years; 

(b) Unless another party notifies the proposing party of any objection and that 

objection is received within seven business days after notification (by fax, by email, or by 

overnight mail), the consultant or expert shall thereafter be allowed to have access to Protected 

Material pursuant to the terms and conditions of this Protective Order; 

(c) In the event of a timely objection, which shall be made in good faith and 

on reasonable grounds, the proposing party shall refrain from disclosure of Protected Material to 

the consultant or expert until the objection has been resolved between the parties or ruled upon 

by the Court; 

(d) The parties shall endeavor in good faith to resolve the dispute without 

calling upon the intervention of the Court. The burden is on the objecting party to seek the 

intervention of the Court by appropriate motion to preclude the proposing party from disclosing 

Protected Material to the consultant or expert. If no such motion is filed within fourteen business 

days of receipt of the objection, the proposing party may disclose Protected Material to the 

consultant or expert as if no objection had been raised; and 

(e) No party shall use its right to object to a proposed consultant or expert to 

interfere with the ability of another party to prepare for trial through the use of consultants and 

experts. 

2.4. Prior to receiving any Protected Material, any persons described in sections (b), 

(c), (e), (f), or (h) of paragraph 2.1 shall be furnished with a copy of this Protective Order and 

shall execute a copy of the "Agreement to be Bound by Protective Order" attached as Exhibit A. 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 7 of 15 PAGEID #: <pageID>
PAGE 8 - STIPULATED PROTECTIVE ORDER 

4031623v2 

A copy of the signed Agreement shall be maintained by counsel for the party providing such 

access. 

2.5. Nothing in this Protective Order shall prevent any counsel of record from utilizing 

Protected Material in the examination of any person who is reasonably alleged to be the author or 

source of the Protected Material or who is reasonably believed to have knowledge relating 

thereto. In addition, (a) Parties and present employees of the parties, or employees of third 

parties, may be examined as a witness at depositions, hearings and trial and may testify 

concerning all Protected Material produced or designated by that party, or by the employee's 

employer if a third party; (b) Former employees of the parties, or former employees of third 

parties, may be examined and may testify concerning all Protected Material produced or 

designated by the party or third party that formerly employed such person and which pertains to 

the period or periods of his/her employment and prior thereto; and (c) Former experts of the 

parties may be examined and may testify concerning all Protected Material produced or 

designated by the respective party that pertains to the subject matter of his/her consultation. 

2.6. Nothing in this Protective Order shall preclude any party from introducing 

Protected Material into evidence at any evidentiary hearing or at trial. However, if anyone 

intends to introduce or refer to Protected Material at any hearing or trial, the party wishing to 

make the disclosure shall provide reasonable advance notice to the producing party so that party 

has an opportunity to object and/or to ask the Court to take appropriate precautionary procedures 

(e.g., clearing the Courtroom, sealing the record, etc.). 

2.7. Nothing in this Protective Order shall bar or otherwise restrict any attorney from 

rendering advice to his/her clients with respect to this litigation and referring to or relying 

generally upon his/her examination of Protected Material, provided that in rendering such advice 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 8 of 15 PAGEID #: <pageID>
PAGE 9 - STIPULATED PROTECTIVE ORDER 

4031623v2 

and in otherwise communicating with his/her clients, the attorney shall not disclose the content 

of such information. 

2.8. All persons in possession of Protected Material shall exercise reasonable and 

appropriate care with regard to the storage, custody, and use of such information in order to 

ensure that the provisions of this Protective Order are observed and the confidential nature of the 

information is maintained. 

2.9. All copies of documents designated for protection under this Order, or any 

individual portion of such a document, shall be marked with the appropriate designation pursuant 

to paragraph 1.4 if the words do not already appear on the copy. All such copies shall be entitled 

to the protection of this Order. The term “copies” shall 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 designated documents or otherwise disclose the 

substance of the designated documents. 

3. CHALLENGES TO CONFIDENTIALITY DESIGNATIONS 

3.1. Any party believing that particular information has been improperly marked, i.e., 

that it is not in fact CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEY EYES 

ONLY, may challenge such designation at any time by raising the issue, in writing to the 

designating party, and specifically identifying, by document identification (Bates) number, by 

deposition page and line, or by other appropriate specific identifier, the information whose 

confidentiality status is challenged. Within ten business days of receipt of such writing, the 

designating party shall either remove or reduce the designation, or respond that it has reviewed 

the matter and continues to maintain the designation in good faith. 

3.2. The parties shall endeavor in good faith to resolve any such dispute without 

calling upon the intervention of the Court. If the designating party maintains its designation and 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 9 of 15 PAGEID #: <pageID>
PAGE 10 - STIPULATED PROTECTIVE ORDER 

4031623v2 

the parties are unable to reach agreement, the challenging party may bring the issue to the Court. 

The party asserting confidentiality shall have the burden of establishing the appropriateness of 

the designation, except that a party claiming that information designated by the other as 

confidential is in the public domain shall have the burden of proving such public knowledge. 

3.3. Challenged information shall be treated as initially designated until the resolution 

of the dispute by the parties or ruling by the Court. 

4. FILING OF PROTECTED MATERIAL 

Parties may not file documents containing protected materials disclosed by another party 

unless agreed to in writing by the party that initially disclosed the protected material or unless 

filed under seal. Notwithstanding the foregoing, this Protective Order does not automatically 

authorize filing protected materials under seal. According to the authority of Procter & Gamble 

Co. v. Bankers Trust Co., 78 F.3d 219 (6th Cir. 1996), no document may be filed with the Court 

under seal without prior permission as to each such filing, upon motion and for good cause 

shown, including the legal basis for filing under seal. Unless the Court orders otherwise, all 

sealed documents shall be filed according to S. D. Ohio Civ. R. 79.3. 

5. TERMINATION OF LITIGATION 

5.1. The obligations of this Protective Order shall survive the termination of the action 

and continue to bind the parties. Within sixty days after termination of this action by judgment, 

settlement, or otherwise from which no appeal can be brought, each party shall destroy, or return 

to the disclosing party if the disclosing party so requests, all documents containing or disclosing 

Protected Material of any other party. Each party's outside litigation counsel shall have the right 

to retain one copy of the pleadings; of motions, memoranda, documents, and papers filed with 

the Court; of deposition transcripts and exhibits; and of any documents constituting work 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 10 of 15 PAGEID #: <pageID>
PAGE 11 - STIPULATED PROTECTIVE ORDER 

4031623v2 

product. Within sixty days after termination of this action, each party shall certify in writing that 

it has complied with this provision. 

6. THIRD PARTY DISCOVERY 

6.1. In the event that any third party shall be called upon, by subpoena or otherwise, to 

provide or produce documents or information considered CONFIDENTIAL or HIGHLY 

CONFIDENTIAL – ATTORNEY EYES ONLY by such third party, such third party may elect 

to have its information treated in accordance with the terms of this Protective Order by so 

notifying counsel for all parties in writing. Upon service of such notice, such third party may 

designate documents and information as CONFIDENTIAL or HIGHLY CONFIDENTIAL – 

ATTORNEY EYES ONLY in the manner set forth in this Protective Order, and such third 

party's designated information shall be protected in the same manner as that of the parties to this 

action. 

7. INADVERTENT DISCLOSURE 

7.1. If a party inadvertently discloses any document or thing containing information 

that it deems CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY 

without designating it pursuant to this Protective Order, the disclosing party shall promptly upon 

discovery of such inadvertent disclosure inform the receiving party in writing, forwarding a 

replacement copy of the inadvertently disclosed material properly marked with the appropriate 

confidentiality designation. The receiving party shall thereafter treat the information as if it had 

been properly marked from the outset and shall make a reasonable effort to retrieve and destroy 

the unmarked version of the inadvertently disclosed material. Disclosure by the receiving party 

to unauthorized persons before being notified of the inadvertent disclosure shall not constitute a 

violation of this Protective Order. Nothing in this Protective Order shall preclude the receiving 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 11 of 15 PAGEID #: <pageID>
PAGE 12 - STIPULATED PROTECTIVE ORDER 

4031623v2 

party from challenging the confidentiality designation of the late-marked material pursuant to the 

provisions of paragraph 3. 

7.2. The inadvertent or mistaken production or disclosure of documents or other 

information subject to the attorney-client privilege, the work product doctrine, or other privilege 

shall not be deemed a waiver of a claim of privilege, either as to the specific information 

disclosed or as to any other related information. If a producing party inadvertently produces or 

otherwise discloses to a receiving party information that is subject to such privilege or immunity, 

the producing party shall promptly upon discovery of such disclosure so advise the receiving 

party in writing and request that the inadvertently disclosed information be returned. The 

receiving party shall return all copies of the inadvertently produced material within five business 

days of receipt of the request. Any notes or summaries referring or relating to any inadvertently 

produced privileged material shall be destroyed. Nothing in this Protective Order shall preclude 

the receiving party returning the inadvertently produced material from seeking an order 

compelling the production of information previously produced inadvertently. 

8. MISCELLANEOUS PROVISIONS 

8.1. If Protected Material in the possession of any receiving party is subpoenaed by 

any court, by any administrative or legislative body, or by any other person purporting to have 

authority to subpoena such information, or is the subject of any discovery request under 

Rules 30-36 of the Federal Rules of Civil Procedure or any comparable rule of court or of any 

adjudicative body (such subpoena or discovery request collectively referred to as a "Third-Party 

Request"), the party to whom the Third-Party Request is directed will not produce such 

information without first giving prompt written notice (including a copy of the Third-Party 

Request) to the attorneys of record for the producing party, by the later of no more than three 

business days after receiving the Third-Party Request or fourteen business days prior to the 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 12 of 15 PAGEID #: <pageID>
PAGE 13 - STIPULATED PROTECTIVE ORDER 

4031623v2 

return date of such Third-Party Request. The party receiving the Third-Party Request must also 

promptly inform in writing the party who caused the Third-Party Request to issue in the other 

litigation or proceeding that some or all the material covered by the Third-Party Request is 

subject to this Protective Order. The party receiving the Third-Party Request must deliver a copy 

of this Protective Order promptly to the party in the other action that caused the Third-Party 

Request to issue. 

8.2. The producing party shall bear the burden and expense of seeking protection in 

court of its own Protected Material, and nothing in this Protective Order should be construed as 

authorizing or encouraging a party receiving a Third-Party Request in this action to disobey a 

lawful directive from another court. Disclosure of information in response to a properly issued 

Third-Party Request shall not constitute a violation of this Protective Order. 

8.3. This Protective Order may be modified only by further Order of the Court, 

whether sua sponte or by agreement of the parties or their counsel and approval by the Court, 

and is without prejudice to the rights of any party to move for relief from any of its provisions, or 

to seek or agree to different or additional protection for any particular material or information. 

8.4. Treatment by counsel or the parties of information designated CONFIDENTIAL 

or HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY as designated shall not be 

construed as an admission by any party that the designated information contains trade secrets or 

other proprietary or confidential information. Conversely, failure to so designate shall not 

constitute a waiver of any party's claims, either within or outside this action, that any such 

documents or information do contain trade secrets or other proprietary or confidential 

information. 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 13 of 15 PAGEID #: <pageID>
PAGE 14 - STIPULATED PROTECTIVE ORDER 

4031623v2 

8.5. No party shall be obligated to challenge the propriety of any designation, and 

failure to challenge a claim of confidentiality at the time of receipt shall not constitute a waiver 

of the right to challenge a confidentiality designation at any later time. 

IT IS SO ORDERED: 

s/Mark R. Abel 

The Honorable Mark R. Abel 

United States Magistrate Judge 

Stipulated and Agreed: 

OKULEY SMITH LLC 

/s/ Matthew J. Schonauer 

Matthew J. Schonauer, #0086361 

John J. Okuley, #0076748 

Telephone: 614.436.0600 

Fax: 614.436.0057 

Email: mschonauer@okuleysmith.com 

Email: jokuley@okuleysmith.com 

Mueller-Smith Building 

7700 Rivers Edge Drive 

Columbus, OH 43235-1355 

Attorneys for Plaintiff Scorecards Unlimited, 

LLC, Third-Party Defendant Progressive 

Innovations, Inc., dba Global Tour Golf, and 

Third-Party Defendant Paul Filings 

ICE MILLER LLP 

/s/ T. Earl LeVere 

T. Earl LeVere, #0063515 

Direct Dial: 614.462.1095 

Fax: 614.228.4847 

Email: elevere@icemiller.com 

250 West Street, Suite 700 

Columbus, OH 43215 

Trial Attorney for Defendant 

Golf ScoreCards, Inc. 

TONKON TORP LLP 

/s/ Jon P. Stride 

Jon P. Stride 

Direct Dial: 503.802.2034 

Direct Fax: 503.972.3734 

Email: jon.stride@tonkon.com 

888 SW Fifth Avenue, Suite 1600 

Portland, OR 97204-2099 

Attorneys for Defendant Golf ScoreCards, Inc. 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 14 of 15 PAGEID #: <pageID>
EXHIBIT A 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

EASTERN DIVISION 

SCORECARDS UNLIMITED, LLC 

Plaintiff, 

v. 

GOLF SCORECARDS, INC. 

Defendant. 

Civil Action No. 2:11cv 906 

Judge Algenon L. Marbley 

Magistrate Judge Mark R. Abel

AGREEMENT TO BE BOUND BY PROTECTIVE ORDER 

I, _______________________, hereby acknowledge that I received a copy of the 

Protective Order in this action. I read and understood the Protective Order and agree to be bound 

by its provisions. I agree not to copy or use any CONFIDENTIAL or HIGHLY 

CONFIDENTIAL – ATTORNEY EYES ONLY information that may be provided to me for any 

purpose other than in connection with my retention in connection with this action, and I agree 

not to reveal any such information to any person not authorized by the Protective Order. 

I further acknowledge and understand that a violation of the Protective Order may subject 

me to penalties of the Court, and I hereby submit to the jurisdiction of the United States District 

Court for the Southern District of Ohio in connection with any proceedings concerning 

enforcement of the Protective Order. 

Dated: 

Case: 2:11-cv-00906-ALM-MRA Doc #: 21 Filed: 02/24/12 Page: 15 of 15 PAGEID #: <pageID>