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Thompson v. Omaha Public Power District

United States District Court, Eighth Circuit

September 10, 2013

HELEN THOMPSON, an individual, Plaintiff,
v.
OMAHA PUBLIC POWER DISTRICT, a political division of the State of Nebraska, Defendant.

CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER

F.A. GOSSETT, District Judge.

This matter having come before the Court upon the Joint Motion for Entry of Protective Order (filing 13) and the Court being duly advised of the same,

IT IS HEREBY ORDERED as follows:

1. The parties anticipate that the parties and certain third parties may seek and provide information which may contain medical information, customer information, proprietary business and financial information, individual tax information, personally identifiable information, certain personnel information, insurance information and/or trade secrets (hereinafter "Confidential Information"). Any documents produced or information provided by a party or third party in response to any discovery request may be designated as "confidential" in the following manner if said documents contain such Confidential Information:

a. By imprinting the word "confidential" on the first page or cover of any document produced;
b. By imprinting the word "confidential" next to or above any answer to any Interrogatory;
c. With respect to portions of a deposition transcript, by making arrangements with the attending court reporter to bind the confidential portion(s) of such transcripts separately and labeling them as "confidential;" and
d. With respect to electronic information or other information that cannot conveniently be labeled, by noting in a separate writing, or in answer to any discovery request or disclosure, that such information is designated as "confidential."

2. To the extent feasible, certain personal identifying information such as Social Security numbers and account numbers may be redacted from documents so as not to require classifying documents which contain such information to be treated as Confidential.

3. All documents and information provided through discovery which are designated as "confidential" by imprinting the word "Confidential" on the documents produced or by specifically referencing said document as Confidential by Bates number shall be subject to the following restrictions:

a. They shall be used only for the purpose of this litigation and not for any business or other purposes whatsoever.
b. They shall not be communicated or disclosed in any manner, either directly or indirectly, to anyone other than:
(1) The attorneys of record and persons employed by them;
(2) Outside experts who have, prior to disclosure, agreed in writing to be bound by the terms of this Protective Order as ...

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