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Randolph v. One Source Temporary Service

United States District Court, D. Kansas

February 20, 2018

LATREISSA DARSHELLE RANDOLPH, Plaintiff,
v.
ONE SOURCE TEMPORARY SERVICE, Defendant.

          La Treissa DarShelle Randolph Pro Se Plaintiff .

          Kevin D. Case, Trevor Bond Counsel for Defendant .

          STIPULATED PROTECTIVE ORDER

          James P. O'Hara U.S. Magistrate Judge

         Plaintiff La Treissa DarShelle Randolph and Defendant Labor Source, LLC d/b/a One Source Staffing and Labor (collectively, the “parties”) agree that during the course of discovery it may be necessary to disclose certain confidential information relating to the subject matter of this action. They agree that certain categories of such information should be treated as confidential, protected from disclosure outside this litigation, and used only for purposes of prosecuting or defending this action and any appeals. The parties jointly request entry of this proposed Protective Order to limit the disclosure, dissemination, and use of certain identified categories of confidential information.

         The parties assert in support of their request that protection of the identified categories of confidential information is necessary because Defendant will be disclosing potential proprietary and trade secret information as well as confidential employee information as part of this employment discrimination case. Such information includes computer records containing information (1) about the identify of its clients/customers, (2) about the contractual relationships between Defendants and its client/customers, including rates charged and other trade secret information, and (3) about the personal information of other employees of Defendant, such as confidential information in their personnel file (including their social security numbers).

         For good cause shown under Fed.R.Civ.P. 26(c), the court GRANTS the parties' joint request and hereby enters the following Protective Order:

         1. Scope. All documents and materials produced in the course of discovery of this case, including initial disclosures, responses to discovery requests, all deposition testimony and exhibits, and information derived directly therefrom (hereinafter collectively “documents”), are subject to this Order concerning Confidential Information as set forth below. As there is a presumption in favor of open and public judicial proceedings in the federal courts, this Order will be strictly construed in favor of public disclosure and open proceedings wherever possible.

         2. Definition of Confidential Information. As used in this Order, “Confidential Information” is defined as information that the producing party designates in good faith has been previously maintained in a confidential manner and should be protected from disclosure and use outside the litigation because its disclosure and use is restricted by statute or could potentially cause harm to the interests of disclosing party or nonparties. For purposes of this Order, the parties will limit their designation of “Confidential Information” to the following categories of information or documents:

a. personnel files of Plaintiff and employees of Defendant;
b. tax returns;
c. proprietary business records, including those from Defendant's “Temps Plus” computer application, as well as information related to the business relationship between Defendant and its clients;
d. financial statements and records; and
e. other records whose disclosure is restricted or prohibited by statute.

         Information or documents that are available to the public may not be ...


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