United States District Court, D. Nebraska
LAURA A. DUHIGG, an individual, Plaintiff,
GOODWILL INDUSTRIES, INC., a Nebraska nonprofit corporation, Defendant.
F.A. Gossett United States Magistrate Judge
This matter came before the Court upon the Joint Stipulation for Protective Order (filing 30) filed by the parties in the above-captioned matter. The Court, being fully advised in the premises, hereby finds as follows:
IT IS HEREBY ORDERED that the Joint Stipulation for Protective Order is granted.
IT IS FURTHER ORDERED that the Parties are limited in their disclosure and use of confidential and proprietary information as follows:
1. In this action, the parties have sought and are seeking through discovery information which is confidential and proprietary in nature. In addition, the parties anticipate there will be questioning concerning confidential information in the course of depositions.
2. The parties agree that the release or disclosure of the Confidential Information outside the scope of this litigation would harm the business interests or otherwise embarrass or invade the privacy of the designating party.
3. The parties jointly stipulate to and request the entry of a Protective Order for the purpose of preventing the disclosure and use of Confidential Information by any party or non-party except as set forth therein.
4. Under the terms of this Protective Order, “Confidential Information” shall include, but not be limited to, any document, file, electronic material, portions of files, transcribed testimony or responses to discovery requests, including any extract, abstract, chart, summary, note or copy made therefrom containing or comprising:
a. Defendant’s company policies and procedures;
b. Defendant’s proprietary business or financial information;
c. Documents and information pertaining to individuals, including Plaintiff, that were or are employed by Defendant or a non-party;
d. Plaintiff’s and/or Defendant’s financial information; and
e. Information related to the medical care and treatment of Plaintiff
5. This Protective Order applies to Confidential Information produced by Plaintiff, Defendant, and any non-party who produces documents as a result of discovery subpoenas or other requests, including, but not limited to, information or ...