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Hannon v. Suntrust Bank

United States District Court, D. Kansas, Kansas City Division.

September 6, 2019


          Ryan M. Paulus, Brittany C. Mehl, CORNERSTONE LAW FIRM, Attorneys for Plaintiff Timothy Hannon

          Brian J. Zickefoose, Kaitlin E. Gallen, POLSINELLI P.C., Ashley Z. Hager, Emily E. Schifter, Admitted Pro Hac Vice

          TROUTMAN SANDERS LLP, Attorneys for Defendant SunTrust Banks, Inc., d/b/a Cohen Financial



         The parties agree during the course of discovery it may be necessary to disclose certain confidential information relating to the subject matter of this action. They agree 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 a 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 discovery in this case may involve production and/or review of confidential information of the parties and non-parties to this action, including personnel records and confidential, proprietary or sensitive business information of SunTrust Banks, Inc., d/b/a Cohen Financial ("SunTrust")[1] as well as medical records, tax information and other private documents or information of Plaintiff. The parties in this action consent to entry of this Consent Protective Order in order to protect the legitimate privacy interests of the parties and non-parties alike, and to provide Plaintiff Timothy Hannon and SunTrust and their respective counsel, certain documents potentially relevant to this action. For good cause shown under Fed.R.Civ.P. 26(c), the court 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 are restricted by statute or could potentially cause harm to the interests of the 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:

• Proprietary, sensitive, or confidential business records
• Financial, tax, and accounting statements and records
• Trade secrets
• Personnel records
• Medical records
• Information identifying current or former customers of SunTrust
• Records whose disclosure is otherwise restricted or prohibited by contract or statute

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

         3. Form and Timing of Designation.

         The producing party may designate documents as containing Confidential Information and therefore subject to protection under this Order by marking or placing the words "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" (hereinafter, "the marking") on the document and on all copies in a manner that will not interfere with the legibility of the document. As used in this Order, "copies" includes electronic images, duplicates, extracts, summaries, or descriptions that contain the Confidential Information. The marking will be applied prior to or at the time the documents are produced or disclosed. Applying the marking to a document does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order. Copies that are made of any designated documents must also bear the marking, except that indices, electronic databases, or lists of documents that do not contain substantial portions or images of the text of marked documents and do not otherwise disclose the substance of the Confidential Information are not required to be marked. By marking a designated document as confidential, the designating attorney thereby certifies that the document contains Confidential Information as defined in this Order.

         4. Inadvertent Failure to Designate.

         Inadvertent failure to designate any document or material as containing Confidential Information will not constitute a waiver of an otherwise valid claim of confidentiality pursuant to this Order, so long as a claim of confidentiality is asserted within ten (10) days business days after discovery of the inadvertent failure.

         5. ...

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