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Padin v. Novartis Consumer Health, Inc.

United States District Court, D. Nebraska

January 20, 2015

GJOEL PADIN, Plaintiff(s),


CHERYL R. ZWART, Magistrate Judge.

WHEREAS the Parties agree that the Parties to this action may consider certain information, documents, and other items discoverable in the above captioned matter, pursuant to Fed.R.Civ.P. 26(c), to be Confidential and that such party may seek to protect such items from disclosure, or to designate such items Confidential to avoid making such information available to non-disclosed party representatives, party employees, non-parties or the general public;

IT IS HEREBY STIPULATED AND AGREED by and between the parties hereto, through their undersigned counsel, that:

1. The following definitions shall apply to the Stipulated Protective Order to be issued in this action:

"Attorneys" means counsel of record;

"Confidential" documents or materials are documents designated pursuant to paragraph 2;

"Protected" documents or materials are documents an/or materials designated pursuant to paragraph 2, and protected in accordance with an Order of this Court;

"Documents" are all materials within the scope of FED. R. CIV. P. 26 and 34;

2. Confidential and/or Protected Documents/Material. As used herein, the term "Confidential and/or Protected Documents/Material" shall mean confidential personal information designated by a party in good faith to be Confidential and/or "information protected by state statute and any Order of this Court." Pursuant to Order of this Court: the following information is also considered Confidential or Protected Material and/or Confidential or Protected Information: Any personnel files or data of any present or past applicants for employment or employees of the Defendant. A party may designate any document, including interrogatory responses, other discovery responses, or transcripts, to be Confidential or Protected that it in good faith contends to constitute or contain Confidential or Protected material or information.

Each party shall designate such material it deems Confidential or Protected by marking all documents with the designations "Confidential" or "Protected". In lieu of marking a document with said designations, the producing party can produce written documentation in which it identifies the documents it designates Confidential or Protected. Only such portions of a deposition transcript as are affirmatively designated in writing by a party to be Confidential or Protected shall be treated as Confidential and/or Protected. The party designating a portion of a deposition transcript, as such, shall provide written notice to all parties by listing the page and inclusive line numbers of the material to be kept Confidential and/or Protected, and shall designate such pages Confidential and/or Protected. In any deposition transcript in which any portion of the transcript has been designated Confidential/Protected by any party, the court reporter, or the party holding the original transcript, shall imprint the word "Confidential" or "Protected" on the front page of the original of the deposition transcript. A deposition containing Confidential and/or Protected information shall not be filed with this Court unless it is filed as provided in Paragraph 8 of this Joint Stipulation for Protection Order. There shall be no need to re-designate documents used in exhibits to transcripts which have been previously designated as Confidential or Protected.

Expert reports and/or summaries containing Confidential and/or Protected information shall be automatically deemed Confidential and/or Protected if the information used to prepare the expert reports and/or summaries included Confidential and/or Protected Materials and/or Confidential and/or Protected information. An expert report may avoid such a designation if the expert report avoids specifically referencing Confidential or Protected information and/or replaces Confidential or Protected information or with non-Confidential/Protected descriptions.

3. Litigation of this Action. As used herein, the phrase "litigation of this action" shall mean preparation for any hearing, trial, or appeal of this action, including but not limited to, pre-trial discovery, trial of this action, dispute resolution, and any judicial proceeding which relates to the subject matter of this action.

4. Use of Confidential or Protected Information. Unless and until agreed by the undersigned parties, or ordered by the Court, all materials and/or information appropriately designated to be Confidential and/or Protected, and any summaries, compilations or other work product which contains or reflects such Confidential/Protected materials, shall be kept and treated as Confidential or Protected and shall be used only for purposes of the litigation of this action.

5. Qualified Persons to Whom Confidential Information May be Disclosed. Confidential or Protected information may only be disclosed or made available on a need-to-know basis by the party receiving such information or ...

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