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Law v. Premier Psychiatric Group, LLC

United States District Court, D. Nebraska

August 29, 2014

JONATHAN LAW, Plaintiff,
v.
PREMIER PSYCHIATRIC GROUP, LLC, NVATION, LLC, and DEEP TMS PROVIDER, LLC, Defendants.

Jeanelle R. Lust, KNUDSEN, BERKHEIMER, RICHARDSON & ENDACOTT, LLP, Lincoln, Nebraska, JONATHAN LAW, Plaintiff.

Larry V. Albers, ALBERS BROWN, Lincoln, NE, PSYCHIATRIC GROUP, LLC; NVATION LLC; AND DEEP TMS PROVIDER, LLC, Defendants.

AGREED CONFIDENTIALITY ORDER

CHERYL R. ZWART, Magistrate Judge.

The Parties to this Agreed Confidentiality Order have agreed to the terms of this Order; accordingly, it is ORDERED:

1. Disclosure of Information. In the course of settlement negotiations between the Parties and discovery, Plaintiff may disclose to Defendants information and documents relating to his earnings history and earning potential at Neuronetics, Inc., including without limitation employment agreements, bonus/incentive compensation plans, stock option agreements, and any information or document which details the wages and other compensation, including benefits, Plaintiff was and would have been entitled to had he remained employed at Neuronetics, Inc. Defendants, including its officers, agents, employees, representatives, and attorneys, will not, either directly or indirectly, divulge, disclose, or communicate such information and documents to any other person or entity, or use such information and documents for any other purpose than the settlement negotiations, discovery and the litigation related to Plaintiff's claims, it being understood by the Parties that all such information and documents shall be treated as strictly confidential. In the course of settlement negotiations between the Parties and discovery, Defendants may disclose to Plaintiff information and documents relating to wages and other compensation, including benefits. Plaintiff, including its officers, agents, employees, representatives, and attorneys, will not, either directly or indirectly, divulge, disclose, or communicate such information and documents to any other person or entity, or use such information and documents for any other purpose than the settlement negotiations, discovery and the litigation related to Plaintiff's claims, it being understood by the Parties that all such information and documents shall be treated as strictly confidential. Furthermore, Plaintiff and Defendants agree that these documents will only be reviewed by the following individuals:

A. Counsel. Counsel for the parties and employees of counsel who have responsibility for the action;
B. Parties. Individual parties and employees of a party but only to the extent counsel determines in good faith that the employee's assistance is reasonably necessary to the conduct of the litigation in which the information is disclosed;
C. Court. The Court and its personnel;
D. Court Reporters and Recorders. Court reporters and recorders engaged for depositions;
E. Contractors. Those persons specifically engaged for the limited purpose of making copies of documents or organizing or processing documents, including outside vendors hired to process electronically stored documents;
F. Consultants and Experts. Consultants, investigators, or experts employed by the parties or counsel for the parties to assist in the preparation and trial of this action but only after such persons have completed the certification contained in Attachment A, Acknowledgment of Understanding and Agreement to Be Bound;
G. Witnesses at Depositions. During their depositions, witnesses in this action to whom disclosure is reasonably necessary. Witnesses shall not retain a copy of documents containing Confidential Information, except witnesses may receive a copy of all exhibits marked at their depositions in connection with review of the transcripts. Pages of transcribed deposition testimony or exhibits to depositions that are designated as Confidential Information pursuant to the process set out in this Order must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Order;
H. Author or recipient. The author or recipient of the document (not including a person who received the document in the course of litigation); and
I. Others by Consent. Other persons only by written consent of the producing party or upon order of the Court and on such ...

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