Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Hollinger v. Christots Montessori School, Inc.

United States District Court, D. Kansas

September 23, 2019

VERONICA HOLLINGER, Plaintiff,
v.
CHRISTOTS MONTESSORI SCHOOL, INC., et al., Defendants. CECILLIA GREEN, Plaintiff,
v.
CHRISTOTS MONTESSORI SCHOOL, INC., et al., Defendants.

          JOHN J. ZIEGELMEYER III KS, CHRISTOPHER J. LAWLER KS ATTORNEYS FOR PLAINTIFFS

          KYLE B. RUSSELL, KS PHILLIP C. THOMPSON, KS JACKSON LEWIS P.C. ATTORNEYS FOR DEFENDANTS

          PROTECTIVE ORDER

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

         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 Plaintiffs have asserted claims of race discrimination and harassment in violation of Title VII, wrongful termination in violation of public policy, assault and battery. Documents that may be produced in this case may contain confidential employment, personal, medical, and/or financial information regarding Plaintiffs and individual Defendants Phillip and Linda Steck and Bethany Enyart, confidential business records, employment or financial information regarding current and/or former employees, clients, or vendors of Defendant Christots Montessori School, Inc. Moreover, some of the documents may contain trade secrets, confidential financial, proprietary, or commercial information of Defendant Christots Montessori School, Inc.

         For good cause shown under Fed.R.Civ.P. 26(c), the court grants the parties’ joint request for Protective Order 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 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:

• Personnel files and other employment files relating to Defendant Christots Montessori School, Inc.’s employees’ performance, discipline, or other matters where the employee may have an expectation of privacy;
• Personally Identifiable Information, including social security numbers, bank or other financial account information, and date of birth of Plaintiffs, individual Defendants Phillip and Linda Steck and Bethany Enyart, and current or former employees of Defendant Christots Montessori School, Inc.;
• Medical information of Plaintiffs, individual Defendants Phillip and Linda Steck and Bethany Enyart, and current and/or former employees of Defendant Christots Montessori School, Inc.;
• Documents submitted to the EEOC and/or the Kansas Human Rights Commission which are not publicly available;
• Proprietary or other confidential business records, including records created by Defendant Christots Montessori School, Inc., and/or relating to or from customers or clients of Defendant Christots Montessori School, Inc.;
• Financial records of Plaintiffs, individual Defendants Phillip and Linda Steck and Bethany Enyart, and Defendant Christots Montessori School, Inc.;
• Proprietary documents or any documents related to any of Defendant Christots Montessori School, Inc.’s trade secrets; and
• Records whose disclosure are restricted or prohibited by statute, agreement, or otherwise.

         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” (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 ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.