United States District Court, D. Nebraska
WOODS & AITKEN, LLP, Terry C. Dougherty, Lincoln, Nebraska, WADE SHOWS, INC., Plaintiff.
ENGLES, KETCHAM, OLSON & KEITH, P.C., Dan H. Ketcham, Michael L. Moran, Omaha, Nebraska, YRC INC., incorrectly identified as YRC WORLDWIDE, INC., and PERRY MARTIN WARE, Defendants/Third-Party Plaintiffs.
Thomas A. Grennan, GROSS & WELCH, P.C., LLO, Omaha, Nebraska, BARBARA BRITO DE LA TORRE, BBT TRANSPORT, INC., a Florida corporation, and KEEP GOING SERVICES CORP., Third-Party, Defendants.
Steven C. Effertz, SCHAFFER, MCINTOSH & EFFERTZ Independence, Missouri, PERRY MARTIN WARE, Defendant/Third-Party Plaintiff.
STIPULATED PROTECTIVE ORDER
CHERYL R. ZWART, Magistrate Judge.
Pursuant to the parties' Joint Motion for Protective Order (Filing No. 111), the parties to this action, 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 Defendants; and/or Defendants' 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; and
(d) 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 ...