United States District Court, D. Nebraska
Mary Kay Green, Lees Summit, MO, Attorney for Plaintiffs.
Heidi A. Guttau-Fox, Baird Holm LLP, Omaha, Nebraska, Attorney for Defendants.
CHERYL R. ZWART, Magistrate Judge.
The parties to this action, Defendants Omaha Public Schools ("OPS") and Principal Barbara Wild ("Wild") (collectively referred to hereinafter as "Defendants") and Plaintiffs Durlean Crayton ("Crayton") and Evie Robinson ("Robinson") (collectively referred to hereinafter as "Plaintiffs"), by their respective counsel, hereby stipulate and request that the Court enter a mutual Protective Order pursuant to Fed.R.Civ.P. 26 as follows:
1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure.
2. The Protective Order shall govern all materials deemed to be "Confidential Information." Such Confidential Information shall include the following:
(a) Any and all documents referring or related to confidential and proprietary human resources or business information; financial records of the parties; compensation of Defendants' current or former personnel; policies, procedures and/or training materials of Defendant OPS; and/or Defendant OPS' organizational structure;
(b) Any documents from the personnel, medical or workers' compensation file of any current or former employee or contractor;
(c) Any documents relating to the medical and/or health information of any of Defendants' current or former employees or contractors;
(d) Any documents which include names or identification of minor children;
(e) Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits.
3. In the case of documents and the information contained therein, designation of Confidential Information produced shall be made by placing the following label or designation on the face of the document and each page so designated "CONFIDENTIAL" or otherwise expressly identified as confidential. Defendants will use their best efforts to limit the number of documents designated Confidential.
4. Confidential Information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business purpose, and shall not be disclosed to any person who is not a qualified recipient. All produced Confidential Information shall be ...