United States District Court, D. Nebraska
Bruce A. Moothart SEYFERTH, BLUMENTHAL & HARRIS, LLC ATTORNEY FOR DEFENDANT
Thomas A. Grennan, #15675 GROSS & WELCH, P.C., L.L.O. ATTORNEY FOR PLAINTIFFS
STIPULATED PROTECTIVE ORDER
Cheryl R. Zwart United States Magistrate Judge
THIS MATTER came before the Court upon the stipulation for entry of this Protective Order as evidenced by the parties' signatures below. The Court, being duly advised of the premises herein, finds that in order to expedite the flow of discovery material, facilitate the prompt resolution of disputes over confidentiality, and adequately protect material to be kept confidential, IT IS HEREBY ORDERED as follows:
1. Documents or information have been and may be requested, produced, or used as an exhibit in this matter, which contain valuable trade secrets, confidential materials, and other proprietary information (hereafter, "Confidential Information").
2. To protect such Confidential Information, the parties and any non-parties who are served with subpoenas may designate as "Confidential" any document(s) produced, or information provided, in response to a discovery request. The designation shall be completed in one of the following manners:
a. By imprinting the word "Confidential" on the front of the document or on the label or cover for any compact disc or flash drive containing Confidential Information;
b. By imprinting the word "Confidential" next to or above any answer to any written discovery response;
c. With respect to deposition transcripts and videos, by making arrangements with the attending court reporter to label such transcripts and videos as "Confidential."
3. All documents and information designated as "Confidential" shall be used only for the purpose of this litigation and not for any other purposes whatsoever. In addition, such documents and information shall be furnished and handled solely in accordance with this Protective Order or subsequent order of the Court.
4. All documents and information designated as "Confidential" (including, but not limited to, any information or testimony discussing, derived from, or referring to such documents or information), shall not be communicated, disclosed, or produced in any manner, either directly or indirectly, to anyone other than:
a. The attorneys of record in this case and their office employees;
b. The parties in this case, including their officers and employees, who have a need to know for purposes of this litigation, provided that any such officer or employee, prior to the disclosure of any documents or information marked as “Confidential, ” agrees to be bound individually by the terms of this Protective Order by executing the Nondisclosure Agreement attached hereto as Exhibit “A”;
c. Outside consulting and retained experts who have, prior to the disclosure of any documents or information marked as "Confidential, " agreed to be bound by the terms of this Protective Order by executing the ...