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Russell v. Werner Enterprises, Inc.

United States District Court, D. Nebraska

February 13, 2015

ANTONIA RUSSELL, individually and on behalf of all those similarly situated, Plaintiff,
v.
WERNER ENTERPRISES, INC., and DOES 1-100 inclusive, Defendants.

Joseph E. Jones, Kathryn A. Dittrick, Elizabeth A. Culhane, Omaha, Nebraska, Attorneys for Defendant Werner Enterprises, Inc.

Justin L. Swidler, Esq., SWARTZ SWIDLER, LLC, Cherry Hill, NJ, Attorneys for Plaintiffs.

David Borgen, Laura L. Ho, Raymond A. Wendell, GOLDSTEIN, BORGEN, DARDARIAN & HO, Oakland, CA, Attorneys for Plaintiffs.

James M. Sitkin, LAW OFFICES OF JAMES M. SITKIN, San Francisco, CA, Attorney for Plaintiffs.

STIPULATED PROTECTIVE ORDER

LYLE E. STROM, Senior District Judge.

Upon the stipulation of the parties, and the Court's acceptance of the same,

IT IS HEREBY ORDERED that a Protective Order is granted and entered as follows:

1. Nondisclosure of Confidential Documents

(a) "Document" means, without limiting its generality, any physical thing containing information or any written, recorded, graphic or other matter, whether produced, printed, reproduced, or stored on paper, cards, tapes, disks, belts, charges, film, computer storage devices or any other medium, including but not limited to all documents necessary to the comprehension or understandings of any designated document, such as computer code or metadata, and includes but is not limited to originals, drafts, redrafts and each separate copy of each document.

(b) Except with prior written consent of the party designating a document to be protected from disclosure or as set forth in Paragraph 2 below, no document designated as CONFIDENTIAL may be disclosed to any person or entity. A party who produces material may designate it as CONFIDENTIAL when the party in good faith believes it contains proprietary information, trade secrets, privileged information, or nonpublic technical, financial, personal or business information. A document designated as CONFIDENTIAL means any document which bears the legend CONFIDENTIAL or, if it is not feasible to label the document, which the producing party indicates via cover letter or otherwise at the time of production is being produced as CONFIDENTIAL.

(c) Except with prior written consent of the party designating a document to be protected from disclosure or as set forth in Paragraph 3 below, no document designated as CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY may be disclosed to any person or entity. A party who produces material may designate it as CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY when the party in good faith believes it contains highly sensitive proprietary information, trade secrets, privileged information, or nonpublic technical, financial, personal or business information. A document designated as CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY means any document which bears the legend CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY or, if it is not feasible to label the document, which the producing party indicates via cover letter or otherwise at the time of production is being produced as CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY.

(d) A party receiving from another party any document that has been designated as CONFIDENTIAL or CONFIDENTIAL - FOR ATTORNEY'S EYES ONLY may object in writing to the designation and must state the reasons for such objection with respect to each item. The parties shall then meet and confer in good faith regarding the designation. If the parties are unable to come to an agreement regarding the designation, the party challenging the designation shall be obligated to file a motion with the Court challenging such designation.

(e) This Stipulated Protective Order shall be without prejudice to the right of any party to: bring before the Court at any time the question of whether any information or documents are confidential; object to the production of any information or documents it reasonably considers not subject to discovery or object to their use at trial; and/or apply to or move the Court for an ...


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