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Filing # 180988 / 23CV001740 / O'DONNELL, JOHN P.
Lake Co Common Pleas Court, Clerk Faith Andrews 05/09/2024 02:39 PM
IN THE COURT OF COMMON PLEAS
LAKE COUNTY, OHIO
BEVCORP LLC,
CASE NO.: 23CV001740
Plaintiff,
JUDGE: JOHN P. O’DONNELL
Vv.
CHRIS RIPOLL, et al.,
Defendants.
STIPULATED PROTECTIVE ORDER
The parties! to this Stipulated Protective Order have agreed to the terms of this Order;
accordingly, it is ORDERED:
1 Scope. This Protective Order (hereinafter “Protective Order” or “Order”) shall
apply to all documents or other information produced in discovery during this litigation (the
“Action”) that the producing person or entity (the “Producing Entity”) has designated as
“CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER” or “ATTORNEYS’ EYES
ONLY -— SUBJECT TO PROTECTIVE ORDER?” (either a “Confidentiality Designation” or
collectively the “Confidentiality Designations”) pursuant to this Order, including but not limited
to the following (collectively the “Confidential Information”): (a) all initial disclosures, (b) all
1 For the purposes of this order the terms "parties" or "party" include Plaintiff and Defendants.
responses to discovery requests, (c) all deposition testimony and exhibits, and (d) all materials
(including documents or testimony) produced by non-parties in response to subpoenas issued in
connection with this matter (including copies, excerpts, and summaries thereof)
2. Purpose. The purpose of this Protective Order is to protect against the unnecessary
disclosure of Confidential Information
3. Disclosure Defined. As used herein, “disclosure” or “to disclose” means to
divulge, reveal, describe, summarize, paraphrase, quote, transmit, or otherwise communicate
Confidential Information, and the restrictions contained herein regarding disclosure of
Confidential Information also apply with equal force to any copies, excerpts, analyses, or
summaries of such materials or the information contained therein, as well as to any pleadings,
briefs, exhibits, transcripts or other documents which may be prepared in connection with this
litigation which contain or refer to the Confidential Information or information contained therein.
4 Designating Material
(a) Designating Material As Confidential: Any party, or any third party
subpoenaed by one of the parties, may designate as Confidential and subject to this Protective
Order any documents, testimony, written responses, or other materials produced in this case if they
contain information that the Producing Entity asserts in good faith is protected from disclosure by
statute or common law, including, but not limited to, confidential personal information, medical
or psychiatric information, trade secrets, personnel records, or such other sensitive commercial
information that is not publicly available. Information that is publicly available may not be
designated as Confidential. The designation of materials as Confidential pursuant to the terms of
this Protective Order does not mean that the document or other material has any status or protection
by statute or otherwise except to the extent and for the purposes of this Order.
(b) Designating Material As Attorneys’ Eyes Only. Any party, or any third
party subpoenaed by one of the parties, may designate as Attorneys’ Eyes Only and subject to this
Protective Order any materials or information that meet the test set forth in Paragraph 4.a, but as
to which the Producing Entity also asserts in good faith that the information is so competitively
sensitive that the receipt of the information by parties to the litigation could result in competitive
harm to the Producing Entity
5. Form and Timing Of Designation.
(a) Documents And Written Materials. The Producing Entity shall designate
any document or other written materials as confidential pursuant to this Order by marking each
page of the material with a stamp setting forth the appropriate Confidentiality Designation, if
practical to do so. The person or entity designating the material shall place the stamp, to the extent
possible, in such a manner that it will not interfere with the legibility of the document. Materials
shall be so-designated prior to, or at the time of, their production or disclosure.
(b) Electronically Stored Information (“ESI”): If a production response
includes ESI, the Producing Entity shall make an effort to include within the electronic files
themselves the Confidentiality Designation to the extent practicable. If that is not practicable, then
the Producing Entity shall designate in a transmittal letter or email to the party to whom the
materials are produced (the “Receiving Party”) using a reasonable identifier (e.g., the Bates range)
any portions of the ESI that should be treated as “CONFIDENTIAL —- SUBJECT TO
PROTECTIVE ORDER,” and any portions of the ESI that should be treated as “ATTORNEYS’
EYES ONLY — SUBJECT TO PROTECTIVE ORDER.”
(c) Deposition Testimony. Deposition testimony will be deemed confidential
only if designated as such when the deposition is taken or within 15 days after receipt of the
deposition transcript. Such designation must indicate which Confidentiality Designation applies,
and must be specific as to the portions of the transcript and/or any exhibits to which that
Confidentiality Designation applies, except that any exhibit that was marked with a Confidentiality
Designation at the time of production, and which still bears that mark at the time of its use in a
deposition, shall be presumed to fall within the provisions of this Order without further
designation.
6. Limitation Of Use.
(a) General Protections. All information that has received a Confidentiality
Designation, including all information derived therefrom, shall be used by any Receiving Party
olely for purposes of prosecuting or defending this Action. A Receiving Party shall not use or
disclose the Confidential Information for any other purpose, including but not limited to any
business, commercial, or competitive purpose. Except as set forth in this Order, a Receiving Party
shall not disclose Confidential Information to any third party. This Order shall not prevent the
Producing Entity from using or disclosing information it has designated as Confidential
Information, and that belongs to the Producing Entity, for any purpose that the Producing Entity
deems appropriate, except that the Producing Entity’s voluntary disclosure of Confidential
Information outside the scope of this Action may impact the protection that this Order would
otherwise provide with regard to such information, once disclosed.
(b) Persons To Whom Information Marked “Confidential” May Be
Disclosed. Use of any information, documents, or portions of documents marked
“CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER,” including all information derived
therefrom, shall be restricted solely to the following persons who agree to be bound by the terms
of this Protective Order, unless additional persons are stipulated by counsel or authorized by the
Court:
1. outside counsel of record for the parties, and the administrative staff
of outside counsel's firms;
2. in-house counsel for the parties, and the administrative staff for each
in-house counsel;
3. any party to this action who is an individual;
4. as to any party to this action who is not an individual, every
employee, director, officer, or manager of that party, but only to the extent
necessary to further the interest of the parties in this litigation;
5. independent consultants or expert witnesses (including partners,
associates and employees of the firm which employs such consultant or expert)
retained by a party or its attorneys for purposes of this litigation, but only to the
extent necessary to further the interest of the parties in this litigation, and only
after such persons have completed the certification attached hereto as
Attachment A, Acknowledgment of Understanding and Agreement to be
Bound;
6. the Court and its personnel, including, but not limited to,
stenographic reporters regularly employed by the Court and stenographic
reporters not regularly employed by the Court who are engaged by the Court or
the parties during the litigation of this action;
7 the authors and the original recipients of the documents;
8. any court reporter or videographer reporting a deposition;
9 employees of copy services, microfilming or database services, trial
support firms, and/or translators who are engaged by the parties during the
litigation of this action;
10. interviewees, potential witnesses, deponents, hearing or trial
witnesses, and any other person, where counsel for a party to this action in good
faith determines the individual should be provided access to such information
in order for counsel to more effectively prosecute or defend this action (as long
as the disclosure occurs in the presence of counsel, and copies, duplicates,
images, or the like are not removed or retained by any interviewee, potential
witness, deponent, or hearing or trial witness), provided, however, that in all
such cases the individual to whom disclosure is to be made has been informed
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that the information contained in the disclosed document(s) is confidential and
protected by Court Order, that the individual understands that he/she is
prohibited from disclosing any information contained in the document(s) to
anyone, or
11. any other person agreed to in writing by the parties.
Prior to being shown any documents produced by another party marked “CONFIDENTIAL —
SUBJECT TO PROTECTIVE ORDER,” any person listed under paragraph 6(b)(3), 6(b)(4), or
6(b)(11) shall be advised that the confidential information is being disclosed pursuant to and
subject to the terms of this Protective Order.
(c) Persons To Whom Information Marked “Attorneys’ Eyes Only” May Be
Disclosed. Use of any information, documents, or portions of documents marked “ATTORNEYS’
EYES ONLY - SUBJECT TO PROTECTIVE ORDER,” including all information derived
therefrom, shall be restricted solely to the following persons who agree to be bound by the terms
of this Protective Order, unless additional persons are stipulated by counsel or authorized by the
Court:
1. outside counsel of record for the parties, and the administrative
staff of outside counsel's firms;
one designated representative from in-house counsel for the
parties;
3. independent consultants or expert witnesses (including partners,
associates and employees of the firm which employs such
consultant or expert) retained by a party or its attorneys for
purposes of this litigation, but only to the extent necessary to
further the interest of the parties in this litigation, and only after
such persons have completed the certification attached hereto as
Attachment A, Acknowledgment of Understanding and
Agreement to be Bound;
4, the Court and its personnel, including, but not limited to,
stenographic reporters regularly employed by the Court and
stenographic reporters not regularly employed by the Court who
are engaged by the Court or the parties during the litigation of
this action;
the authors and the original recipients of the documents;
6. any court reporter or videographer reporting a deposition;
7, employees of copy services, microfilming or database services,
trial support firms, and/or translators who are engaged by the
parties during the litigation of this action
8. any other person agreed to in writing by the parties
Prior to being shown any documents produced by another party marked “ATTORNEYS’ EYES
ONLY — SUBJECT TO PROTECTIVE ORDER,” any person listed under paragraph 6(c)(8) shall
be advised that the confidential information is being disclosed pursuant to and subject to the terms
of this Protective Order.
7, Inadvertent Production. Inadvertent production of any document or information
with a Confidentiality Designation shall be governed by Ohio Rule of Evidence 502. Pursuant to
subsections (d) and (e) of that Rule, the parties agree to, and the Court orders, protection of
Protected Information against claims of waiver (including as against third parties and in other
Federal and State proceedings) in the event such information is produced during the course of the
Litigation, whether pursuant to a Court order, a parties’ discovery request, or informal production,
as follows:
a. the production of documents or electronically stored information (“ESI”)
(including, without limitation, metadata) subject to a legally recognized
claim of privilege or other protection from production or other disclosure
(collectively, “Protected Information”), including without limitation the
attorney-client privilege and work-product doctrine, shall in no way
constitute the voluntary disclosure of such Protected Information;
b. the production of Protected Information shall not result in the waiver of any
privilege or protection associated with such Protected Information as to the
receiving party, or any third parties, and shall not result in any waiver of
protection, including subject matter waiver, of any kind;
C if any document or ESI (including, without limitation, metadata) received by
a party is on its face clearly subject to a legally recognizable privilege,
immunity, or other right not to produce such information, the Receiving Party
will promptly notify the Producing Entity in writing that it has discovered
Protected Information, identify the Protected Information by Bates Number
range, and return or sequester such Protected Information until the Producing
Entity confirms whether it does indeed assert any privilege protecting this
information. Once the Producing Entity asserts privilege over such
Protected Information (as described in Subparagraph (e) below), the
Receiving Party will return, sequester, or destroy all copies of such
Protected Information, along with any notes, abstracts or compilations of
the content thereof, within ten (10) business days of notice from the
Producing Entity;
d. upon the request of the Producing Entity, the Receiving Party will promptly
disclose the names of any individuals who have read or have had access to
the Protected Information;
e if the Producing Entity intends to assert a claim of privilege or other
protection over Protected Information identified by the receiving party, the
Producing Entity will, within ten (10) business days of receiving the
Receiving Party’s written notification, inform the Receiving Party of such
intention in writing and shall provide the Receiving Party with a log for
such Protected Information that is consistent with the requirements of the
Ohio Rules of Civil Procedure, setting forth the basis for the claim of
privilege, immunity or basis for non-disclosure, and in the event, if any
portion of the Protected Information does not contain privileged or
protected information, the Producing Entity shall also provide to the
Receiving Party a redacted copy of the Protected Information that omits the
information that the Producing Entity believes is subject to a claim of
privilege, immunity or other protection;
f. if, during the course of the litigation, a party determines it has produced
Protected Information, the Producing Entity may notify the Receiving Party
of such production in writing. The Producing Entity’s written notice must
identify the Protected Information by Bates Number range, the privilege or
protection claimed, and the basis for the assertion of the privilege and shall
provide the receiving party with a log for such Protected Information that is
consistent with the requirements of the Ohio Rules of Civil Procedure,
setting forth the basis for the claim of privilege, immunity or basis for non-
disclosure, and in the event any portion of the Protected Information does
not contain privileged or protected information, the Producing Entity shall
also provide to the receiving party a redacted copy of the Protected
Information that omits the information that the Producing Entity believes is
subject to a claim of privilege, immunity or other protection. The Producing
Entity must also demand the return of the Protected Information. After
receiving such written notification, the Receiving Party must, within ten
(10) business days of receiving the written notification, return, sequester, or
destroy the specified Protected Information and any copies, along with any
notes, abstracts or compilations of the content thereof;
g. a Receiving Party’s return, sequestration, or destruction of such Protected
Information as provided in the Subparagraphs above will not act as a waiver
of the Receiving Party’s right to move for the production of the returned,
sequestered, or destroyed Protected Information on grounds that the
Protected Information is not in fact subject to a viable claim of privilege or
other protection. However, the Receiving Party is prohibited and estopped
from arguing that the Producing Entity’s production of the Protected
Information in this matter acts as a waiver of applicable privileges or
protections, that the disclosure of the Protected Information by the Producing
Entity was not inadvertent, that the Producing Entity did not take reasonable
steps to prevent the disclosure of the Protected Information, or that the
Producing Entity did not take reasonable steps to rectify such disclosure; and
h. nothing contained herein is intended to or shall limit a Producing Entity’s
right to conduct a review of documents or ESI (including, without
limitation, metadata), for relevance, responsiveness, and/or the segregation
of privileged and/or protected information before such information is
produced to the Receiving Party;
1 prior to production to another party, all copies, electronic images, duplicates,
extracts, summaries, or descriptions (collectively “copies”) of documents
marked with a Confidentiality Designation under this Order, or in any
individual portion of such a document, shall be affixed with the same
Confidentiality Designation if it does not already appear on the copy. All
such copies shall thereafter be entitled to the protection of this Order. The
term “copies” shall not include indices, electronic databases, or lists of
documents provided these indices, electronic databases, or lists do not
contain substantial portions or images of the text of confidential documents
or otherwise disclose the substance of the confidential information contained
in those documents.
8. Filing Materials Containing Information With A Confidentiality Designation.
In the event a party seeks to file with the Court any confidential information subject to protection
under this Order, that party must take appropriate action to ensure that the document receives
proper protection from public disclosure, including: (a) filing a redacted document with the
consent of the party who designated the document as confidential; (b) where appropriate (e.g., in
relation to discovery and evidentiary motions), submitting the document solely for in camera
review; or (c) when the preceding measures are inadequate, seeking permission to file the
document under seal by filing a motion for leave to file under seal. The burden of demonstrating
the need for and appropriateness of a sealing order is borne by the moving party. Regardless of
whether the parties agree, it remains the Court’s independent obligation to determine whether a
seal is appropriate for any given document or portion thereof. Any proposed sealing, even when
compelling reasons exist, must be narrowly tailored to serve compelling reasons.
When a party to this Order seeks to file documents which it believes may warrant sealing,
but is not the party who may be prejudiced by the document or documents becoming part of the
public record, the filing party shall provide the potentially-prejudiced party or parties, or any
potentially-prejudiced third party or parties, with written notification of its intent to file such
documents at least (14) fourteen days before doing so. After being provided such notice, the
potentially harmed party or parties will then have (7) seven days to file with the Court a motion
for sealing. The Court will rule on the motion as promptly as possible
9. Attorneys Allowed To Provide Advice. Nothing in this Order shall bar or
otherwise restrict any attorney for any party from rendering advice to his or her client with respect
to this case or from doing anything necessary to prosecute or defend this case and furthering the
interests of his or her client, except for the disclosure of the Confidential Information as proscribed
in this Order.
10. Excluding Others From Access. Whenever information bearing a Confidentiality
Designation pursuant to this Protective Order is to be discussed at a deposition, the person or entity
that designated the information may exclude from the room any person, other than persons
designated in Paragraph 6 of this Order, as appropriate, for that portion of the deposition.
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11. No Voluntary Disclosure To Other Entities. The parties or anyone acting on their
behalf may not voluntarily disclose any Confidential Information to any state or federal law
enforcement or regulatory agency, or any employee thereof, except in this litigation as set forth in
Paragraph 6 of this Order or as otherwise commanded by law or provided in this Order. Nothing
in this Order shall prevent a party from providing information in its possession in response to a
valid order or subpoena from a law enforcement or regulatory agency requiring the production of
such information, except that, prior to such production, the party producing the information shall
provide as much advance notice as possible to the person or entity that designated the material as
confidential to facilitate that party’s efforts to preserve the confidentiality of the material, if
warranted.
12. Disputes As To Designations. Each party has the right to dispute the
Confidentiality Designation asserted by any other party or subpoenaed person or entity in
accordance with this Protective Order. If a party believes that any documents or materials have
been inappropriately designated by another party or subpoenaed party, that party shall confer with
counsel for the person or entity that designated the documents or materials. As part of that
conferral, the designating person or entity must assess whether redaction is a viable alternative to
complete non-disclosure. If any party challenges the Confidentiality Designation of any document
or information, the burden to properly maintain the designation shall, at all times, remain with the
person or entity that made the designation to show that said document or information should
remain protected pursuant to Ohio Civ.R. 26(C). In the event of disagreement, then the designating
person or entity shall file a motion pursuant to Ohio Civ.R. 26(C). A party who disagrees with the
designation must nevertheless abide by that designation until the matter is resolved by agreement
of the parties or by order of the Court.
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13. Information Security Protections. Any person in possession of Confidential
Information received from another person or entity in connection with this Action shall maintain
an information security program that includes reasonable administrative, technical, and physical
safeguards designed to protect the security and confidentiality of such Confidential Information,
protect against any reasonably anticipated threats or hazards to the security of such Confidential
Information, and protect against unauthorized access to or use of such Confidential Information.
14, If a Receiving Party discovers a breach of security, including any actual or
suspected unauthorized access, to Confidential Information subject to this Order, they shall: (1)
notify the person or entity who designated the materials under the terms of this Order of such
breach; (2) investigate and take reasonable efforts to remediate the effects of the breach; and (3)
provide sufficient information about the breach that the Producing Entity can reasonably ascertain
the size and scope of the breach. The Receiving Party agrees to cooperate with the Producing
Entity or law enforcement in investigating any such security incident. In any event, the Receiving
Party shall promptly take all necessary and appropriate corrective action to terminate the
unauthorized access.
15. All Trials Open To Public. All trials, and certain pretrial proceedings and
hearings, are open to the public (collectively a “Public Hearing” or “Public Hearings”). Absent
further order of the Court, there will be no restrictions on any Party’s ability to the use during a
Public Hearing any document or information that has marked with a Confidentiality Designation
or documents or information derived therefrom that would disclose such confidential information.
However, if a party intends to present at a Public Hearing any document or information that has
been so designated, the party intending to present such document or information shall provide
advance notice to the person or entity that made the Confidentiality Designation at least (5) five
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days before the Public Hearing by identifying the documents or information at issue as specifically
as possible (i.e., by Bates Number, page range, deposition transcript line, etc.) without divulging the
actual documents or information. Any person may then seek appropriate relief from the Court
regarding restrictions on the use of such documents or information at trial, or sealing of the
courtroom, if appropriate.
16, No Waiver Of Right To Object. This Order does not limit the right of any party
to object to the scope of discovery in the above-captioned action
17, No Determination Of Admissibility. This Order does not constitute a
determination of the admissibility or evidentiary foundation for the documents or a waiver of any
party’s objections thereto.
18. No Admissions. Designation by either party of information or documents under the
terms of this Order, or failure to so designate, will not constitute an admission that information or
documents are or are not confidential or trade secrets. Neither party may introduce into evidence
in any proceeding between the parties, other than a motion to determine whether the Protective
Order covers the information or documents in dispute, the fact that the other party designated or
failed to designate information or documents under this Order.
19, No Prior Judicial Determination. This Order is based on the representations and
agreements of the parties and is entered for the purpose of facilitating discovery in this action.
Nothing in this Order shall be construed or presented as a judicial determination that any
documents or information as to which counsel or the parties made a Confidentiality Designation
is in fact subject to protection under Ohio Civ. R. 26(C) or otherwise until such time as the Court
may rule on a specific document or issue.
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20. Order Subject To Modification. This Order shall be subject to modification by
the Court on its own motion or on motion of a party or any other person with standing concerning
the subject matter.
21. Parties May Consent To Disclosure. Nothing shall prevent disclosure beyond the
terms of this Order if all parties consent to such disclosure, or if the Court, after notice to all
affected parties, permits such disclosure. Specifically, if and to the extent any party wishes to
disclose any Confidential Information beyond the terms of this Order, that party shall provide all
other parties with reasonable notice in writing of its request to so disclose the materials. If the
parties cannot resolve their disagreement with respect to the disclosure of any Confidential
Information, then a party may petition the Court for a determination of these issues. In addition,
any interested member of the public may also challenge the designation of any material as
confidential, pursuant to the terms of this paragraph.
22. Return Of Materials Upon Termination Of Litigation. Upon the written request
and expense of the Producing Entity, within 30 days after the entry of a final judgment no longer
subject to appeal, or the execution of any agreement between the parties to resolve amicably and
settle this case, the parties and any person authorized by this Protective Order to receive
confidential information shall return to the Producing Entity, or destroy, all information and
documents subject to this Protective Order, unless the specific document or information has been
offered into evidence or filed without restriction as to disclosure. The party requesting the return
of materials shall pay the reasonable costs of responding to its request. The party returning or
destroying the documents or other information shall certify that it has not maintained any copies
of confidential information, except as permitted by this Order.
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23. Counsel Allowed To Retain Copy Of Filings. Counsel Allowed To Retain Copy
Of Filings. Nothing in this Protective Order shall prevent outside counsel for a party from
maintaining in its files a copy of any filings in the Action, including any such filings that
incorporate or attach information bearing Confidentiality Designations, for archival purposes
Moreover, an attorney may use his or her work product in subsequent litigation provided that such
use does not disclose any information or documents subject to this Order.
SO ORDERED.
Dh, PO Peanalll
Judge John P. O’ Donnell
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STIPULATED AND AGREED:
/s/ John W. Hofstetter, per email approval /s/ Zachary B. White
By By:
Ryan J. Morley, Bar No. 77452 David P. Pierce (0061972)
morley@littler.com Marc L. Fleischauer (0064580)
John W. Hofstetter, Bar No. 87731 Zachary B. White (0096014)
jhofstetter@littler.com COOLIDGE WALL CO., L.P.A.
Andrew N. Domozick, Bar No. 101167 33 W. First Street, Suite 600
adomozick@littler.com
adomozick(@itter.com Dayton, Ohio 45402
Tel: 937-223-8177; Fax: 937-223-8711
LITTLER MENDELSON, P.C. Email pierce@coollaw.com
Key Tower fleischauer@coollaw.com
127 Public Square white@coollaw.com
Suite 1600
Cleveland, OH 44114-9612 Attorneys for Defendants Christopher M.
Telephone: 216.696.7600 Ripoll and Beverage Consultants, LLC dba
Facsimile: 216.696.2038 First Op Seamer Services
Attorneys for Plaintiff
Bevcorp, LLC /s/ Brian J. Kelly, per email approval
By
BrianJ. Kelly (0063679)
FRANTZ WARD LLP
200 Public Square, Suite 3000
Cleveland, OH 44114
(216) 515-1660 — Phone
(216) 515-1650 — Fax
Email bkelly@frantzward.com
Attorneys for Defendants Audrey Hiser,
Steven Rodriguez, Zechary Grant, and
Pablo Giles Rodiguez
CERTIFICATE OF SERVICE
A copy of the foregoing Stipulated Protective Order was filed electronically this 7 day of
May, 2024 using the Court’s electronic filing system. Notice of this fling will be sent to all
participants by operation of the Court’s electronic filing system. Parties may access this filing
using the Court’s system.
/s/ Zachary B. White
Attorney at Law
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ATTACHMENT A
IN THE COURT OF COMMON PLEAS
LAKE COUNTY, OHIO
BEVCORP LLC,
CASE NO.: 23CV001740
Plaintiff,
JUDGE: JOHN P. O’DONNELL
Vv.
CHRIS RIPOLL, et al.,
Defendants.
ACKNOWLEDGEMENT OF UNDERSTANDING
AND
AGREEMENT TO BE BOUND
The undesigned hereby acknowledges that he/she has read the Protective Order dated
in the above-captioned action and attached hereto, understands the terms thereof, and
agrees to be bound by its terms. The undersigned submits to the jurisdiction of the Court of
Common Pleas for Cuyahoga County, Ohio in matters relating to the Protective Oder and
understands that the terms of the Protective Order obligate him/her to use documents designated
“CONFIDENTIAL — SUBJECT TO PROTECTIVE ORDER” or “ATTORNEYS’ EYE ONLY —
SUBJECT TO PROTECTIVE ORDER” in accordance with the Order solely for the purposes of
the above-captioned action, and not to disclose any such documents or information derived directly
therefrom to any other person, firm or concern
The undersigned acknowledges that violation of the Protective Order may result in
penalties for contempt of court.
Name:
Job Title
Employer:
Business Address:
Date:
Signature
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