IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

JAMES EDWARDS,

Plaintiff,

Civil Action 2:17-cv-236

v. Chief Judge Edmund A. Sargus, Jr.

Magistrate Judge Jolson

CRAIG ALAN MATTHEWS, et al.,

Defendants.

STIPULATED PROTECTIVE ORDER

This stipulated protected order covers all medical records, including psychological and 

psychiatric records of James Edwards and each individual defendant which have been or will be 

produced or obtained in discovery in this case. These records shall be subject to discovery 

between and among the parties but shall otherwise be kept confidential.

These confidential medical records shall be held strictly confidential by counsel for each 

party and may only be disclosed to counsel for each party, the parties, and expert witnesses who 

need access to the material. None of the documents covered by this protective order may be 

disclosed to any other person, or member of the public. If any document subject to this 

protective order is produced, copied, used in a deposition, or at trial, it shall be marked 

prominently with the word “CONFIDENTIAL.”

Any “CONFIDENTIAL” designation is subject to challenge by any party or non-party 

with standing to object. Before filing any motions or objections to a confidentiality designation 

with the Court, the objecting party shall have an obligation to meet and confer in a good faith 
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effort to resolve the objection by agreement. If agreement is reached confirming or waiving the 

“CONFIDENTIAL” designation as to any documents subject to the objection, the designating 

party shall serve on all parties a notice specifying the documents and the nature of the agreement.

Before a party files any document subject to this order or uses it at trial or in any other 

way so as to make it a potentially public record, the party shall either move to file the document 

“under seal” with prior permission of the Court, or give seven days’ notice to all other parties of 

their intent to make the document public so another party may file a motion to seal the document. 

This Protective Order does not authorize filing protected materials under seal. 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. See 

Procter & Gamble Co. v. Bankers Trust Co., 78 F.3d 219 (6th Cir. 1996). 

At the conclusion of the litigation, all written materials, including copies made thereof, 

subject to this protective order shall be returned to counsel who produced the materials.

IT IS SO ORDERED.

Date: May 30, 2017 /s/ Kimberly A. Jolson

KIMBERLY A. JOLSON

UNITED STATES MAGISTRATE JUDGE

Agreed to by: 

s/ Adam G. Gerhardstein 

Alphonse A. Gerhardstein (0032053) 

Adam G. Gerhardstein (0091738) 

Attorney for Plaintiffs 

Gerhardstein & Branch, Co LPA 

441 Vine Street, Suite 3400 

Cincinnati, Ohio 45202 

(513) 621-9100 

Fax (513) 345-5543 

agerhardstein@gbfirm.com 

adamgerhardstein@gbfirm.com 

Counsel for Plaintiff 

s/ Andrew N. Yosowitz 

Andrew N. Yosowitz (0075306) 

ayosowitz@isaacwiles.com 

Isaac, Wiles, Burkholder & Teetor, LLC 

2 Miranova Place, Suite 700 

Columbus, Ohio 43215 

Tel: 614-221-2121; Fax: 614-365-9516 

Attorney for Defendants