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Harrold v. United States

United States District Court, D. Nebraska

April 8, 2015

CONNIE L. HARROLD and GEOFFREY L. HARROLD, Plaintiffs,
v.
UNITED STATES OF AMERICA and CITY OF OMAHA, NEBRASKA, a municipal corporation, Defendants.

STIPULATED PROTECTIVE ORDER

THOMAS D. THALKEN, Magistrate Judge.

This matter is before the court on the parties' Motion for Entry of Stipulated Protective Order (Filing No. 40). Upon a showing of good cause in support of the entry of a protective order to control the discovery and dissemination of confidential or proprietary information in this case (hereafter collectively referred to as "Confidential Information"),

IT IS ORDERED:

The parties' Motion for Entry of Stipulated Protective Order (Filing No. 40) is granted.

IT IS FURTHER ORDERED:

1. Confidential Information will include confidential or proprietary business information. For purposes of this Order, the following categories of documents and information will generally be considered "Confidential Information" and subject to this Protective Order:

• Plaintiff Connie L. Harrold's medical or healthcare records;
• Plaintiffs' tax, financial, wage, and employment records;
• Confidential or proprietary business information.

2. Confidential Information subject to this Protective Order may, depending on the content, be included in a variety of documents, including but not limited to, Agency records, documents produced pursuant to written discovery, answers to interrogatories, responses to requests for admission, deposition testimony, including all copies thereof, and other information disclosed in the context of discovery of this case by either party or disclosed pursuant to the discovery procedures created by the Federal Rules of Civil Procedure.

3. Confidential Information shall not be disclosed or used for any purpose except the preparation and trial of this case, Connie L. Harrold and Geoffrey L. Harrold v. United States of America and City of Omaha, Nebraska, a municipal corporation, and will not be used in any other litigation.

4. Confidential Information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:

a. attorneys actively working on this case;

b. any person who previously received or ...


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