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Krogh v. Manpower U.S. Inc.

United States District Court, District of Nebraska

December 30, 2014

KRISTY KROGH, Plaintiff,
v.
MANPOWER U.S. INC., a Delaware Corporation and ZOETIS LLC, a Delaware Limited Liability Company Defendants.

Susan M. Foster NE #24192 JACKSON LEWIS P.C. And Emily M. Petroski JACKSON LEWIS P.C. Admitted pro hac vice Attorneys for Defendant Zoetis, Inc

Terry A. White Carlson, Burnett Law Firm Plaintiff’s Attorney Brian E. Spang McGuire, Woods Law Firm Admitted pro hac vice And Robert B. Evnen Woods Aitken Law Firm Attorneys for Defendant Manpower US, Inc. And

JOINT CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER

CHERYL R. ZWART UNITED STATES MAGISTRATE JUDGE

The Parties, by and through their respective counsel, enter into this Joint Confidentiality Agreement and Stipulated Protective Order (“Confidentiality Agreement”) and thereby agree to the following terms and conditions:

I. Definitions

1. Confidential Information.

As used in this Confidentiality Agreement, “Confidential Information” shall mean: (a) Defendants’ current or former employee personnel documents; (b) Defendants’ investigation documents; (c) Defendants’ Customers’ personal identification information; (d) Defendants’ Customers’ financial information; (e) Defendants’ operational policies and procedures; (f) Defendants’ confidential and proprietary personnel and business related information; (g) Defendants’ internal notes, emails and other communications regarding former or current employees; and (h) Plaintiffs’ financial and medical records. Use of Confidential Information, or any deposition testimony related to same, during this judicial proceeding shall be governed by this Confidentiality Agreement.

2. Highly Confidential/Attorneys’ Eyes Only:

To the extent it is otherwise discoverable, Confidential Information regarding trade secrets or highly sensitive confidential or proprietary commercial or financial information (including without limitation information about Defendants’ legal fee rates and structure; Defendants’ client names and/or contact information; Defendants’ current and former employees’ personal contact information; customer contracts; formulae and intellectual property; sales, profit and loss; or the Defendants’ financial information) may be further designated as “Highly Confidential/Attorneys’ Eyes Only.”

II. Procedure for Identification of Confidential Information

3. Other than as set forth in paragraphs four and five below, the designation of information as “Confidential Information” or “Highly Confidential/Attorneys’ Eyes Only” shall be made by placing or affixing on the designated information, in a manner that will not interfere with its legibility, the word “CONFIDENTIAL” or “Highly Confidential/Attorneys’ Eyes Only, ” as applicable. The designation of information as Confidential Information or “Highly Confidential/Attorneys’ Eyes Only” shall be made prior to, or contemporaneously with, the production or disclosure of said information or on the record during any deposition. However, should the disclosing party discover after disclosure that the words “CONFIDENTIAL” or “Highly Confidential/Attorneys’ Eyes Only” were inadvertently omitted from a document or documents, or no designation as such was made upon the record at a deposition, then upon written notice of same, the other party shall return all such documents. The disclosing party shall then mark the returned documents, or relevant portions of the deposition transcript, as “CONFIDENTIAL” or “Highly Confidential/Attorneys’ Eyes Only” and produce them to the other party within seven (7) business days of the disclosing party’s receipt of same.

4. Any commercial, financial, business or regulatory records of a party shall be deemed Confidential Information whether or not marked “CONFIDENTIAL” or “Highly Confidential/Attorneys’ Eyes Only” and shall be governed by this Confidentiality Agreement.

5. Any personnel files, payroll or employment records of any employee or former employee of a party shall be deemed Confidential Information whether or not marked “CONFIDENTIAL” or “Highly Confidential/Attorneys’ Eyes ...


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