United States District Court, D. Nebraska
JOEY SHASKE, a minor child, by and through his Parents, natural guardians, and next friends, JODIE SHASKE and JOSHUA SHASKE, Plaintiff,
CARMIKE CINEMAS, INC., a Delaware Corporation, Defendant.
CONSENT PROTECTIVE ORDER
CHERYL R. ZWART, Magistrate Judge.
Discovery in this case may involve the production and/or review of confidential medical records of Plaintiff Joey Shaske ("Shaske") or sensitive business and financial information of Carmike Cinemas, Inc. ("Carmike") (collectively referred to as the "Parties"), as well as to nonparties to this action. The Parties to this action consent to the entry of this Consent Protective Order ("Order") to protect the legitimate privacy and confidentiality interests of the Parties and non-parties alike, as well as to provide the Parties and their respective counsel certain documents relevant to the subject matter of this action. Accordingly, good cause having been shown, IT IS HEREBY ORDERED that:
1. For purposes of this Order, "Confidential Information" may include, but is not limited to:
a. Personnel records of any employee or former employee of Carmike;
b. Any document relating to the medical condition of former or present employees of Carmike;
c. Any document that contains trade secrets information protected from disclosure by statute or confidential or sensitive commercial, business, financial, or proprietary information of Carmike;
d. Salary, payroll, tax, insurance, or benefit information concerning current and former employees of Carmike;
e. Any document relating to Shaske's medical condition;
f. Other non-public personal information, including but not limited to social security numbers, unlisted home addresses, or unlisted home telephone or cell phone numbers; and
g. Any other documents that a party in good faith designates as "Confidential Information, " whether by stamping or marking the documents as "Confidential" or by including a header at the first page of the document indicating that it contains information that the party considers to be confidential.
Confidential Information may consist of documents or information produced by either party or third parties; information disclosed, discussed, or revealed in a deposition or other proceeding in this action; information disclosed or revealed in an interrogatory or document request response; or other information produced through the discovery process in this case.
2. All documents produced by any party that contain Confidential Information and bear the label "CONFIDENTIAL" shall be treated and maintained as such by all persons to whom such documents are disclosed pursuant to the terms of this Order. All Parties and counsel for all Parties will maintain the security of such documents.
3. Documents and other materials designated as "Confidential" shall be used only in connection with this case and may not be disclosed wholly, in part, or in substance to persons not Parties to this lawsuit except as set forth herein.
4. Documents and other materials designated "Confidential" pursuant to the terms of this Order may only be disclosed for purposes of this litigation to counsel; employees and professional assistants of counsel; Parties; expert witnesses and identified trial witnesses; focus group participants and other trial consultants; deponents; the Court, including the judges, their law clerks, the Clerk of Court and any other ...