Boards of Trustees of Ohio Laborers' Fringe Benefit Programs v. Cash Services LLC

Filing 16

STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Kimberly A. Jolson on 2/7/2017. (agm)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
BOARDS OF TRUSTEES OF THE OHIO
LABORERS’ FRINGE BENEFIT
PROGRAMS,
Plaintiff,

CASE NO. 2:16-cv-874
JUDGE GRAHAM
MAGISTRATE JUDGE JOLSON

v.
CASH SERVICES, LLC,
Defendant.
STIPULATED PROTECTIVE ORDER
Upon stipulation of Plaintiff Boards of Trustees of the Ohio Laborers’ Fringe Benefit
Programs, its related entities/benefits trusts, i.e., the Ohio Laborers’ District Council – Ohio
Contractors’ Association Insurance Fund, the Laborers’ District Council and Contractors’
Pension Fund, the Ohio Laborers’ Training and Apprenticeship Trust Fund, Ohio Laborers’
District Council – Ohio Contractors’ Association Cooperation and Education Trust (collectively,
“Plaintiff”), and Defendant Cash Services, LLC (“Defendant”) (Plaintiff and Defendant shall be
referred to collectively as the “Parties”), the Court hereby enters this Protective Order pursuant
to Rule 26 of the Federal Rules of Civil Procedure in an effort to facilitate the exchange of
information related to this litigation while protecting private and confidential information
belonging to Defendant and Defendant’s employees and independent contractors, including their
Social Security Numbers (“SSN”):
A.

Scope. The Plaintiff agrees:
1.

that Plaintiff will not use, reveal, or otherwise disclose any SSNs or

documents containing SSNs produced during this litigation, except for legitimate purposes in
connection with this litigation, and only as necessary and reasonable. Any disclosure of

documents containing SSNs described above which will be accessible to any third parties must
be appropriately redacted to hide all references to SSNs.
2.

that Plaintiff will not use, reveal or otherwise disclose Defendant’s reports

of contribution to other funds and any certified payrolls provided by Defendant, except for
legitimate purposes in connection with this litigation, and only as necessary and reasonable.
B.

Inadvertent Disclosure.

If Plaintiff inadvertently, or without authorization,

discloses any SSNs described above, Plaintiff must immediately notify counsel for Defendant,
take all reasonable actions to mitigate the disclosure, and provide all reasonable assistance to
remedy the unauthorized disclosure.
C.

Sanctions. The Court may order appropriate sanctions for violations of this order.

D,

Return or Destruction. Upon conclusion of this litigation, all materials and

documents within the Scope of this Protective Order produced during this litigation shall be
returned to Defendant or such materials and documents shall be certified to have been destroyed.
IT IS SO ORDERED.
Date: February 7, 2017

/s/ Kimberly A. Jolson
KIMBERLY A. JOLSON
UNITED STATES MAGISTRATE JUDGE

Approved and agreed:
/s/ Steven L. Ball
Steven L. Ball, Esq. (0007186)
Ball & Tanoury
1010 Old Henderson Rd. – Suite 1
Columbus, OH 43220
Tel: [phone]
Trial Attorney for Plaintiffs

/s/ Dan L. Makee
Dan L. Makee (0029602)
McDonald Hopkins LLC
600 Superior Avenue, East
Suite 2100
Cleveland, Ohio 44114
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]
Trial Attorney for Defendant
Cash Services, LLC