Roland v. Convergys Customer Management Group, Inc. et al

Filing 12

STIPULATED PROTECTIVE ORDER. Signed by Judge Susan J. Dlott on 10/2/15. (mb)

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
WESTERN DIVISION

RACHEL M. ROLAND, on behalf of
herself and all others similarly situated,
Plaintiff,

CASE NO. I:15cv325

Judge Dlott
CONVERGYS CUSTOMER

MANAGEMENT GROUP INC.,
CONVERGYS CORPORATION,
Defendants.

STIPULATED PROTECTIVE ORDER FOR THE
PROTECTION OF CONFIDENTIAL INFORMATION

Plaintiff Rachel M. Roland and Defendants Convergys Customer Management Group,

Inc. and Convergys Corporation (collectively, "Convergys"), subject to approval by the Court,
hereby stipulate to the following Order relating to confidential business and other proprietary
information.
IT IS HEREBY STIPULATED THAT:

Each party to this proceeding (including potential future class members) or any
subsequent appeals and anyone else who may subscribe to this Stipulated Protective Order
("Order") agrees as follows:
PURPOSE

The parties recognize that preparation and hearing of this action may require the

discovery of confidential and/or proprietary materials containing proprietary business, personnel,
trade secret or financial information, other information subject to confidentiality requirements or
such other sensitive commercial information that is not publicly available. The parties desire to