United States District Court, D. Nebraska
Joshua P. Wunderlich Robert G. Pahlke, Kyle J. Long, Robert O. Hippe, THE ROBERT PAHLKE LAW GROUP, Scottsbluff, Nebraska, Counsel for Plaintiff.
Scott Parrish Moore, BAIRD HOLM LLP, Omaha, Nebraska, Counsel for Defendant.
JOINT STIPULATED PROTECTIVE ORDER
LYLE E. STROM, Senior District Judge.
1. DEFINITIONS. Limitations under this Protective Order on the use or disclosure of documents, deposition testimony or other discovery designated as "Confidential" shall apply to (a) all information, copies, extracts and complete or partial summaries prepared or derived from such documents or testimony; (b) portions of deposition transcripts, answers to interrogatories, responses to requests for admissions, responses to requests for production, initial disclosures and exhibits thereto which directly refer or directly relate to any such information, documents, copies, extracts or summaries; and (c) portions of briefs, memoranda or any other writing filed with the Court and exhibits thereto which directly relate to any such information, documents, copies, extracts or summaries.
2. CONFIDENTIAL DOCUMENTS/INFORMATION.
a. Plaintiff seeks to protect from disclosure confidential physical or mental health information of the Plaintiff, and his family members, including but not limited to, medical conditions, medical treatment, medical bills or charges, and insurance claims, benefits, and/or payments.
b. Defendants seek to protect from disclosure certain personal and sensitive information regarding the employees of Defendants relating to this lawsuit.
c. Before produced documents are copied or inspected, the producing party may stamp as "Confidential" or similar notation on any document or deposition testimony which contains such sensitive information. Documents may also be designated as "Confidential" by written notice to opposing counsel which identifies the documents so designated by Bates number. Documents designated "Confidential, " deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any purpose other than this litigation and will not be disclosed except pursuant to court order entered after notice, to anyone except:
i. Counsel who have signed this Order approving it as to form and content, attorneys who are employed by Plaintiff, retained outside counsel, in house counsel, law clerks, secretaries or paralegals directly involved in the conduct of this litigation;
ii. Experts and consultants retained by a party to this action for purposes of assisting in the preparation or presentation of claims or defenses;
iii. Any deposition or trial witness, during the course of deposition or trial testimony, when necessary to the testimony of such witness;
iv. Any person who was involved in the preparation of the document;
v. The Court, Court personnel, court reporters and similar personnel;
vi. The named parties to this case, excluding their agents and/or representatives except those identified ...