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Inserra v. Jewish Federation of Omaha, Inc.

United States District Court, Eighth Circuit

January 13, 2014

PATRICIA INSERRA, Plaintiff,
v.
JEWISH FEDERATION OF OMAHA, INC. d/b/a THE JEWISH FEDERATION OF OMAHA, Defendant.

PROTECTIVE ORDER

F.A. GOSSETT, Magistrate Judge.

The matter comes before the Court on the Joint Motion and Stipulation for Protective Order submitted by Plaintiff and Defendant. (Filing 26.) The Court, being fully advised in the premises, finds as follows:

1. It is anticipated that in the course of discovery in this action (the "Litigation"), either Plaintiff or Defendant (collectively, the "Parties" and individually, a "Party") may produce documents or information containing or constituting private, sensitive, confidential, proprietary or other information concerning a Party to the Litigation or concerning persons who are not parties to this Litigation (hereinafter, "Confidential Information").

2. This Protective Order shall be applicable to all Confidential Information designated as "Confidential" or "Attorney's Eyes Only" in accordance with the procedures set forth in this Protective Order by the Parties, by any additional persons or entities hereafter served with summons or entering an appearance herein or produced by any non-party in response to a subpoena. For the purposes of this Protective Order, the term "documents" includes, without limitation, documents or materials, items, testimony elicited in depositions, or other information, including information produced in electronic format, and also includes any derivative, compilation or summary of any "documents, " and the information therein.

3. Any Party to this Litigation or any other person who produces or supplies information, documents or tangible items in the course of discovery (hereafter "Designating Party" or "Producing Party") may designate as "Confidential" or "Attorney's Eyes Only" subject to this Protective Order any documents, material or information that it reasonably and in good faith believes constitutes private, sensitive, confidential, proprietary or similarly protected information; however, nothing in this Protective Order shall be construed as a waiver by any Party of the right to assert a timely, good faith and reasonable objection to any request for discovery or to production of documents or information on the basis that the information sought is private, sensitive, confidential, proprietary or similarly protected information.

4. Confidential Information which a Producing Party produces, either voluntarily or by Court Order, shall be designated as Confidential Information either by marking "CONFIDENTIAL" or "ATTORNEY'S EYES ONLY" on the face of the original or photocopy of the document, information or tangible item ("tangible item" includes a CD or other electronic form of information) being produced and upon each page so designated, if practicable, or by identifying the Bates Number, page number or range of numbers constituting or including Confidential Information. With respect to a deposition, a Party or counsel for a non-party deponent may designate testimony or any exhibits to a deposition as Confidential Information by identifying such testimony or exhibits as Confidential Information during the deposition or, within thirty (30) days following receipt of the deposition transcript, by identifying in a writing sent to all counsel and to the deponent, if not a party, the portions of the transcript and any exhibits which are being designated as Confidential Information.

5. Confidential Information shall not be furnished or disclosed to any person except as provided for herein, and shall be used solely for the purposes of this Litigation and shall not be used for any business or other purpose.

6. Confidential Information may be disclosed only to the following persons:

A. This Court and its personnel.
B. Counsel of record in this Litigation.
C. Plaintiff and officers of Defendant and representatives of Plaintiff and Defendant who have a reasonable need to know the Confidential Information in order to testify, or to participate in litigation decision-making, further provided that person shall execute the Confidentiality Agreement, attached hereto as Exhibit "A". Counsel shall maintain a copy of each such Confidentiality Agreement, and shall provide if requested, a copy of the signed Agreement to counsel for the requesting Parties.
D. Other attorneys employed by the Parties and/or employees of the counsel's law firms to the extent reasonably necessary to render professional services in the Litigation; provided that prior to disclosure, counsel of record have advised such other attorneys and employees of their obligations under this Order.
E. Any consultant, investigator or independent expert (collectively "Expert") who is assisting in the preparation or trial of this Litigation, but only to the extent reasonably necessary to enable such Expert to render such assistance; provided that, prior to disclosure, each such Expert shall execute the Confidentiality Agreement, attached hereto as Exhibit "A." Counsel of record retaining such consultant shall maintain a copy of each such Confidentiality Agreement during the course of this Litigation.
F. Persons testifying in depositions (including, without limitation, persons preparing to testify in such depositions) to the extent the Confidential Information was authored by, addressed to, or received by the person or party testifying; provided that, prior to disclosure, each such person shall execute the Confidentiality Agreement, attached hereto as Exhibit "A." Counsel shall maintain a copy of each such Confidentiality Agreement, and shall provide, if requested, a copy of the signed Agreement to counsel for the requesting Parties. As to any witness shown documents or information designated as Confidential Information, disclosure shall not include the physical transfer to or ...

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