United States District Court, D. Nebraska
MICHELLE BAUER, Plaintiff. s/Jennifer L. Turco Meyer Jennifer L. Turco Meyer, #23760 Dyer Law PC, LLO and Raymond R. Aranza, #18523 Marks Clare & Richards, LLC
AETNA LIFE INSURANCE COMPANY, a Connecticut corporation; and COX ENTERPRISES, INC., WELFARE BENEFITS PLAN, Defendants. s/Heidi Guttau-Fox Heidi A. Guttau-Fox, #21570 Attorney for Defendants Baird Holm LLP
STIPULATED PROTECTIVE ORDER
Thomas D. Thalken United States Magistrate Judge
The Parties to this action, Plaintiff Michelle Bauer ("Bauer"), and Defendants Aetna Life Insurance Company ("Aetna") and Cox Enterprises, Inc., Welfare Benefits Plan ("Cox") (collectively referred to hereinafter as "Defendants"), 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." Any party to this action may designate as "Confidential" documents and information such as:
(a) Any and all documents referring or relating to confidential and proprietary 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 structures;
(b) Any and all documents that constitute or contain trade secrets or otherwise constitutes business proprietary and/or confidential material, or other confidential research, development, or commercial information, whether embodied in physical objects, documents, or other factual knowledge of persons, and specifically shall include but not necessarily be limited to, financial data, personal or business information of third parties, consumer surveys, marketing studies, databases of business contacts, databases of business document templates, policies, procedures, rules and regulations, bulletins, memoranda, training materials, and any and all writings reflecting same;
(c) Any and all documents related to third party independent medical reviewers, including but not limited to their compensation, findings, and background information;
(d) Any and all documents, including contractual agreements between Aetna and its clients; and
(e) Any personal and/or protected health information of Plaintiff.
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 ...