IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

MELISSA McFADDEN, : CIVIL ACTION NO. 18cv544

:

Plaintiff, : 

: JUDGE SARGUS

v. :

: MAGISTRATE JUDGE JOLSON

: 

CITY OF COLUMBUS, :

Defendant :

STIPULATED PROTECTIVE ORDER

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”), 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-partiesin response to subpoenas 

issued in connection with this matter, 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.

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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 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.

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

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interfere with the legibility of the document. Materials shall be so-designated 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 days after receipt 

of the deposition transcript. Such designation must be specific 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.

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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 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 inhouse counsel;

3. any party to this action who is an individual;

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 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;

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6. the Court and its personnel, including, but not limited to, stenographic 

reporters regularly employed by the Court and stenographic reporters 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;

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 Fed. R. Evid. 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

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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 (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;

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f. if, during the course of the litigation, a party determines it has produced Protected 

Information, the Producing Entity may notify the Receiving Party 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 theevent 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 ofthe 

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; and

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;

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 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.

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8. Filing Materials Containing Information Designated Confidential. In the event 

a party seeks to file with the Court any confidential information subject to protection under this 

Order, that party 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.

Any motion to file a documentsubject to this Order underseal 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 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 it believes may warrant sealing, 

but is not the party who may be prejudiced by the document or documents becoming part of the 

public record, 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 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.

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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 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

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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 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

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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.

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 the 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 trade secrets.

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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 on its own motion 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 so 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 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.

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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.”

SO ORDERED.

Dated:

U.S. District Judge/U.S. Magistrate Judge

AGREED TO:

/s/ /s/

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By: /s/ Samuel M. Schlein

Samuel M. Schlein (0092194)

(sschlein@marshallforman.com)

John S. Marshall (0015160)

(jmarshall@ marshallforman.com)

Edward R. Forman (0076651)

(eforman@ marshallforman.com)

MARSHALL AND Forman LLC

250 Civic Center Dr., Suite 480

Columbus, Ohio 43215-5296

(614) 463-9790

Fax (614) 463-9780

ATTORNEYS FOR PLAINTIFF

By: /s/ Westley M. Phillips per consent 

Westley M. Phillips (0077728)

Susan E. Williams (0073375)

Assistant City Attorneys

77 N. Front St., 4 Floor

Columbus, Ohio 43215-9013

(614) 645-7385

Attorneys for Defendants

ATTORNEYS FOR DEFENDANT

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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

MELISSA McFADDEN, : CIVIL ACTION NO. 18cv544

:

Plaintiff, : 

: JUDGE SARGUS

v. :

: MAGISTRATE JUDGE JOLSON

: 

CITY OF COLUMBUS, :

Defendant :

FORM PROTECTIVE ORDER 

ATTACHMENT A

The undersigned hereby acknowledges that [he/she] has read the Protective Order dated 

[INSERT DATE OF OPERATIVE 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 abovecaptioned action, and not to disclose any such documents or information derived directly therefrom 

to any other person, firm, or concern.

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The undersigned acknowledges that violation of the Protective Order may result in 

penalties for contempt of court.

Name:

Job Title:

Employer:

Business Address:

Date: 

Signature

2

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