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Harrington v. City of Lincoln

United States District Court, D. Nebraska

January 13, 2016

SHANE HARRINGTON and KALI RECORDS, LLC, Plaintiffs,
v.
CITY OF LINCOLN, NEBRASKA, a municipal corporation, TOM CASADY, JIM PESCHONG, and RUSSELL FOSLER, individually, and in their official capacities as employees of the City of Lincoln, Defendants.

PROTECTIVE ORDER

LYLE E. STROM, Senior Judge

This matter is before the Court for consideration on parties’ Joint Stipulation for Protective Order. The Court finds that the parties are engaged in discovery which may involve, among other things, the production or disclosure of information deemed confidential. Accordingly, the Court finds that this Protective Order should be and hereby is granted as follows:

FACTS

1. The records requested by the Plaintiffs include the Defendants’ employee and personnel records.

2. The records are confidential because they contain personal information of the Defendants and their employees.

PROTECTIVE ORDER

The Court hereby enters a Protective Order with the following terms:

1) Confidential Information. This Protective Order applies to all Confidential Information produced by a party in this case, whether revealed in a document, deposition, an interrogatory answer or otherwise. All documents and every portion thereof produced by the Defendants or that relate to or contain the Defendants’ and their employees’ employment and personnel files shall constitute CONFIDENTIAL information for the purposes of this Order and shall be used by the receiving party only for the preparation for and conduct of proceedings herein and not for any business or other purpose whatsoever. The CONFIDENTIAL information shall not be used or Disclosed by Plaintiffs’ Attorneys, or anyone else for any purpose unrelated to this litigation or for any business or competitive purpose. Disclosure other than as provided for herein shall first require written consent of the Producing Party, or by order of the Court. Plaintiffs’ Attorneys shall maintain a list of documents disclosed and to whom. Plaintiff’s Attorneys shall also require anyone receiving confidential documents to agree to the terms of this Agreement. Should Plaintiffs and/or their Attorneys question whether documents designated as Confidential Documents are truly confidential, they should first contact the Producing Party to resolve the issue. If the issue cannot be resolved, Plaintiffs’ Attorneys may petition the Court for an order declaring that the document is not subject to the conditions of this Protective Order. The Plaintiffs’ Attorneys shall be responsible for instructing witnesses, consultants, and outside counsel assisting in preparation of the case that disclosure of the Confidential Documents is prohibited as set forth herein.

2) Qualified Recipients. For the purposes of this Order, persons authorized to receive “CONFIDENTIAL” information (hereinafter “qualified recipient”) shall include only:

(a) The Parties, including any members, council members, officers, board members, directors, employees, or other legal representatives of the parties;

(b) Legal counsel representing the Defendants and legal counsel representing the Plaintiffs, and members of the paralegal, secretarial, or clerical staff who are employed by, retained by, or assisting such counsel;

(c) Consulting or testifying expert witnesses assisting any legal counsel in the preparation of this case and staff and assistants employed by the consultant or testifying expert;

(d) The parties’ insurers and their staff and assistants, members, officers, board members, directors ...


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