United States District Court, D. Nebraska
STIPULATED PROTECTIVE ORDER
F.A. GOSSETT, Magistrate Judge.
WHEREAS, the parties to this proceeding, Shirley Claassen, M.D. and Kenneth Pollock, Plaintiffs, and General Casualty Company of Wisconsin, Defendant, recognize that during the course of this proceeding issues may arise which may require disclosure of confidential information or information that is or should be protected from public dissemination. The parties wish to protect such confidential and protected information and documents by the terms of the following Stipulation and Protective Order;
WHEREAS such information should not be released into the public domain, but rather should be treated as confidential pursuant to the privacy interests of the parties;
WHEREAS the parties have, through counsel, agreed to be bound by and stipulated to the entry of this Order to prevent unnecessary disclosure or dissemination of such confidential information;
WHEREAS the Court has found that the parties should respect and recognize the privacy interests of each other by the avoidance of any release of the confidential information, documents or things that are produced in this action;
IT IS HEREBY ORDERED that the terms and conditions of this Order shall govern the production and handling of the documents and other information produced by any party in this action:
1. This Order is entered for the purposes of this case and shall remain in full force and effect unless modified by an Order of this Court. Without limiting the foregoing, this Order shall survive and remain in full force and effect after the termination of this litigation.
2. This Order shall become effective upon the signature of a United States Magistrate Judge or United States District Judge of the United States District Court for the District of Nebraska.
3. Nothing in this Order shall limit or preclude the parties from applying to the Court to modify the terms of this Order, or for such further or additional Protective Orders as the Court may deem appropriate.
4. Portions of documents and materials produced or provided by any party and that are marked "CONFIDENTIAL, " shall be considered confidential material. The producing party shall designate clearly on any document or other material produced that its contents should be confidential, by labeling or identifying each document or other material as "CONFIDENTIAL, " or by including the designation "CONFIDENTIAL" within the electronic file name of any electronically stored information (ESI) or any materials produced in electronic format. Any ESI or electronically produced materials designated "CONFIDENTIAL" by the producing party and which are printed out for purposes of discovery, depositions, or hearings in this matter shall be appropriately marked as "CONFIDENTIAL" on the pages of the hard copies by the party intending to utilize such materials, if not already so marked by the producing party.
5. Documents or ESI designated or marked as "CONFIDENTIAL" shall be revealed only to and used by:
A. This Court and its staff;
B. Parties and counsel for parties, along with the support staff of counsel. As used herein, "counsel" shall mean those attorneys who are members or associates of the respective law firms employed by each party, and who are charged with the responsibility for and actively engaged in preparation of this matter, as well as any of counsel's respective secretaries, legal assistants, paralegals and other staff.
C. Independent experts or consultants retained by counsel or parties, and deposition or trial witnesses who may examine "CONFIDENTIAL" materials in connection with discovery and the presentation of evidence in court proceedings in this matter, and who, before receiving such ...