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Klone v. United States

United States District Court, D. Nebraska

April 28, 2016

CHARLES R. KLONE and REGINA KLONE, Husband and Wife, Plaintiffs,
v.
UNITED STATES OF AMERICA, Defendant.

STIPULATED PROTECTIVE ORDER

Cheryl R. Zwart United States Magistrate Judge

Upon a showing of good cause in support of the entry of a protective order to control the discovery and dissemination of confidential or proprietary information in this case (hereafter collectively referred to as “Confidential Information”), IT IS ORDERED THAT:

1. Confidential Information will include confidential or proprietary business information. For purposes of this Order, the following categories of documents and information will generally be considered “Confidential Information” and subject to this Protective Order:

• Plaintiff’s medical or healthcare records;
• Confidential or proprietary business information.

2. Confidential Information subject to this Protective Order may, depending on the content, be included in a variety of documents, including but not limited to: Agency records, documents produced pursuant to written discovery, answers to interrogatories, responses to requests for admission, deposition testimony, including all copies thereof, and other information disclosed in the context of discovery of this case by either party or disclosed pursuant to the discovery procedures created by the Federal Rules of Civil Procedure.

ATTACHMENT A

3. Confidential Information shall not be disclosed or used for any purpose except the preparation and trial of this case, Charles and Regina Klone v. United States of America, and will not be used in any other litigation.

4. Confidential Information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:

a. attorneys actively working on this case;
b. any person who previously received or authored the materials;
c. persons regularly employed or associated with the attorneys actively working on the case;
d. Plaintiffs Charles Klone and Regina Klone;
e. treating medical providers, expert witnesses, and consultants retained in ...

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