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Vallejo v. Amgen, Inc.

United States District Court, D. Nebraska

April 11, 2016

JAN VALLEJO, INDIVIDUALLY AND AS PERSONAL REPRESENTATIVE OF THE ESTATE OF STEVE VALLEJO Plaintiff,
v.
AMGEN INC., ET AL., Defendants.

STIPULATED PROTECTIVE ORDER

WHEREAS, during the course of this action, the parties or others may be required to produce in discovery information which a party or the person or entity from whom discovery is sought considers to be confidential or trade secret business, financial, or technical information, information protected from discovery by third party rights of privacy or applicable law, or other trade secret, proprietary or confidential information; and

WHEREAS, the parties hereto desire to agree to a protective order for the protection of such information, and documents containing such information, during the pendency of this action and thereafter, and also for resolution of other issues which have or may arise in connection with this litigation;

THEREFORE, IT IS ORDERED that:

1. Terms: The terms defined in this Paragraph shall have the meanings provided. Defined terms may be used in the singular or plural.

1.1 “Producing Party” means the party, or person/entity other than a party, being asked to produce documents or information considered by that party or person to be Confidential Information, or a party asserting a confidentiality interest in information produced by others.

1.2 “Receiving Party” means that party/person/entity receiving or requesting production of Confidential Information.

1.3 “Confidential Information” means information, whether or not embodied in any physical medium, including all originals and copies of any document and/or information, used by the Producing Party in or pertaining to its business, or information pertaining to third-party privacy interests, which information the Producing Party reasonably and in good faith judgment believes contains or discloses a trade secret or other confidential research, development, or commercial information.

1.4 “Litigation Documents” means all pleadings, motions, affidavits and related papers, all documents produced or exchanged in the course of this action or any settlement negotiations, all written discovery responses and all transcripts and testimony given in depositions, in hearings or at trial.

1.5 “Termination” means the dismissal of this Action, or entry of final judgment or expiration of all periods to appeal or seek judicial review of this action.

2. Redaction of Documents

2.1 Notwithstanding the provisions of paragraph 1 above, Producing Party may redact from any materials any trade secrets, commercial, technical information, or privacy-related information, including but not limited to:

(a) manufacturing dimensions or tolerances;
(b) chemical formulas or methods of synthesization;
(c) product specifications;
(d) manufacturing methods and processes;
(e) information concerning Defendants’ products not at issue in this Action;
(f) names and any information that would identify clinical trial subjects or patients (other than the parties), and any other privacy-related information that is required to be redacted by law (such as 21 C.F.R. 20.63);
(g) names and any information that would identify the voluntary reporter or any other person associated with an adverse event involving a human drug, biologic, or medical device product, including, but not limited to, the name, address, institution, or any other information that would lead to the identities of the reporter or the persons identified in the report, and any other privacy-related information that is required to be redacted by law (such as 21 C.F.R. 20.63); and
(h) any other information protected from disclosure by statute.

2.2 Any discovery materials so redacted shall have “REDACTED” stamped on each page from which material or information has been redacted.

2.4 Should the producing party redact information, that party shall provide the requesting party with a log which allows the requesting party to reasonable ascertain the nature of the privilege. This log shall be provided within 60 days after the production of the redacted materials. The parties acknowledge and agree that reasonable extensions to this deadline will be afforded if good cause exists. In the event that portions of a document are redacted such as an email chain, the producing party shall provide sufficient information to understand the nature of each redaction in the document.

2.3 If there is a dispute whether any redacted material qualifies for redaction under this paragraph, counsel may move for ruling, which may require this Court’s in camera inspection of a document on the issue ...


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