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Delgado v. GGNSC Grand Island Lakeview LLC

United States District Court, D. Nebraska

March 22, 2016

TARA DELGADO, Plaintiff,
v.
GGNSC GRAND ISLAND LAKEVIEW LLC d/b/a GOLDEN LIVING CENTER GRAND ISLAND LAKEVIEW, Defendant.

Kathleen M. Neary, VINCENT M. POWERS & ASSOCIATES, Charles M. Roesch, Esq., Andrew B. Millar, Esq., DINSMORE & SHOHL LLP, Aaron A. Clark, Ruth A. Horvatich, MCGRATH NORTH MULLIN & KRATZ, PC., Attorneys for Defendant GGNSC Grand Island Lakeview LLC d/b/a Golden Living Center Grand Island Lakeview.

JOINT STIPULATION FOR PROTECTIVE ORDER

CHERYL R. ZWART UNITED STATES MAGISTRATE JUDGE.

This Protective Order is entered pursuant to Federal Rule of Civil Procedure 26(c). One purpose of this Protective Order is to comply with the Health Insurance Portability and Accountability Act (HIPAA), specifically HIPAA Regulation 45 C.F.R. § 164.512(e), which dictates the protections necessary to permit disclosure of protected health information in the course of a judicial proceeding. The parties hereby stipulate and agree as follows:

1. Definition of Confidential Information.

The following shall constitute Confidential Information:

(a) Personnel information including, but not limited to, personnel files; documents or information that contain personnel information of any past, present, or prospective employees of Defendant; performance ratings; supervisory notes, discipline reports, information relating to employment policies; and documents or information which the parties or the person(s) to which such information refers may claim, understand, or believe to be private, secret, or personal entrusted to someone in the course and scope of employment;
(b) Documents, lists, and information containing the social security numbers, employee identification numbers, and any other information personal to the individuals listed;
(c) Non-public financial information including, but not limited to, information regarding earnings, profits, income, and/or financial status, including wage and benefit documentation or information regarding any employee or former employee of Defendant;
(d) Non-public information of Defendant that contains company policies and procedures, trade secrets, future business plans, market analysis, confidential research, development, commercial or other proprietary information;
(e) Non-public documents and/or information relating to any investigations or studies of any aspect of Defendant’s business or operations by a third party consultant, person and/or entity;
(f) Any other information, documents, or things subject to protection under the law, including, but not limited to, Federal Rule of Civil Procedure 26;
(g) Any testimony specifically revealing Confidential Information as defined in Paragraphs 1(a)-(e) above;
(h) Extracts and summaries prepared from such materials set forth in Paragraphs 1(a)-(e) above;
(i) Those portions of briefs, affidavits, and depositions, including exhibits thereto, which contain or restate the ...

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