Doe v. The Ohio State University et al

Filing 37

Stipulated PROTECTIVE ORDER regarding Deposition of Non-party Jane Roe.. Signed by Judge Gregory L. Frost on 12.15.15. (kn)

Case: 2:15-cv-02830-GLF-TPK Doc #: 36 Filed: 12/15/15 Page: 1 of 3 PAGEID #: 430

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
John Doe,

:

Plaintiff.

:

Case No. 2:15-cv-02830

vs.

:

Judge Gregory L. Frost

The Ohio State University, et al.,

:

Magistrate Terence P. Kemp

Defendant.

:

STIPULATED PROTECTIVE ORDER REGARDING DEPOSITION OF NONPARTY JANE ROE
Now come the parties and non-party Jane Roe, by and through counsel, and
hereby make the following stipulations with respect to Jane Roe’s deposition set for
January 14, 2016, at 10 a.m. and the subpoena duces tecum served upon her by Plaintiff
John Doe:
1.

Any request for document production to Jane Roe as outlined in the subpoena
duces tecum directed to and served upon her is suspended pending the production
of documents by The Ohio State University. Plaintiff reserves the right to renew
the request for production and Jane Roe reserves all objections.

2.

With respect to Jane Roe’s deposition, the scope of inquiry shall be limited to the
investigation, hearing, and other actions taken by The Ohio State University on the
allegations that John Doe violated the Code of Student Conduct. This specifically
includes:
a.

Accommodations received by Jane Roe as a result of Jane Roe’s allegations

Case: 2:15-cv-02830-GLF-TPK Doc #: 36 Filed: 12/15/15 Page: 2 of 3 PAGEID #: 431

that she was the victim of alleged misconduct by John Doe including, but
not limited to, Jane Roe's academic review board proceedings;
b.

Communications with The Ohio State University Office of Student Life and
any other employees of The Ohio State University concerning Jane Roe’s
allegations that she was the victim of alleged misconduct by John Doe.

3.

The scope of inquiry at the deposition shall not include:
a.

The substance of Jane Roe’s allegations that she was the victim of alleged
misconduct by John Doe, inclusive of all communications regarding the
alleged incident unrelated to the investigation, hearing, and other actions
taken by The Ohio State University;

b.

Any medical conditions, prescribed medications, medical treatment or
counseling Jane Roe has sought or received as a result of her allegations of
misconduct against John Doe, including all communications with any
healthcare provider.

4.

Jane Roe reserves the right to object to any line of questioning as provided by
relevant law.

5.

John Doe shall not be permitted to attend the deposition of Jane Roe.

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6.

The transcript of the deposition of Jane Roe shall be deemed Confidential and may
be filed or used by the parties in accordance with the previously issued Protective
Order in this case.

IT IS SO STIPULATED.
/s/ Joshua Engel

IT IS SO ORDERED.
/s/

GREGORY L. FROST

United States District Judge
/s/ Christina Corl
/s/ Reid Caryer