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Carnrick v. Riekes Container Corp.

United States District Court, D. Nebraska

July 19, 2016

AMY CARNRICK, Plaintiff,
v.
RIEKES CONTAINER CORPORATION, ROBERT RICHEY, individually, and as Vice President of Sales of Riekes Container Corporation, Defendants.

          STIPULATED PROTECTIVE ORDER

          Hon. Thomas D. Thomas Judge.

         PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE 26(c), THE PARTIES HEREBY STIPULATE AND AGREE TO THE FOLLOWING PROTECTIVE ORDER:

         1. Facts Establishing Good Cause and "Confidential Information, " Defined.

         Plaintiff Amy Camrick ("Plaintiff') brings this lawsuit containing numerous counts and allegations against Riekes Container Corporation ("Riekes Container") and Robert Richey ("Richey") (collectively, "Defendants"). Defendants deny Plaintiffs allegations. It is anticipated that non-public confidential financial, educational, medical and/or personnel information about Plaintiff, as well as non-public confidential fmancial, educational, medical and/or personnel information about current and/or former employees of Riekes Container and Richey, and non-public confidential information regarding the performance, finances, taxes, compensation data, employee persoimel information, clients, business strategies, and operation of the parties may be requested through discovery (hereafter, "Confidential Information"). The parties recognize that the public disclosure of such Confidential Information may cause injury to Plaintiff and Defendants, and the release of Confidential Information may affect the privacy of Plaintiff, the Defendants, and/or current or fonner employees of Riekes Container who are not parties to this Action. This Order protects Plaintiff and the Defendants and prohibits the public release of Confidential Information, while allowing the parties access to information each seeks to discover and minimizing any potential harmful effects on either the parties or non-parties. The Court finds that the parties properly seek to protect such Confidential Information as well as to protect all parties and non-parties from any annoyance or embarrassment that unrestricted disclosure may potentially cause.

         2. Limited Use of Confidential Information.

         "Confidential Information, " as defined above in paragraph 1, shall be used by the parties only for purposes of preparing for and conducting the Action (including the trial and any appeals) styled Carnrick v. Riekes Container Corp., etal, Case No. 8:16-CV-0095 (hereinafter the "Action").

         3. Designating Information As Confidential.

         Any party to this Action may designate information as "Confidential Information" consistent with the above definition by affixing the legend "Confidential" to every page of the document so designated or otherwise affixing such legend in a readily visible location on any other item so designated. In the event that Confidential Information is produced without a "Confidential" designation, any party may seek to have it designated as "Confidential" by advising the other party of the same within thirty (30) days. With respect to Confidential Information contained in testimony, any party may designate portions of testimony as "Confidential" by notifying all counsel in writing of the page(s) and line(s) of such testimony within thirty (30) days of receipt of a copy of die transcript, or such otiier time period as may be mutually agreed upon by me parties. All testimony shall be deemed confidential for a period of mirty (30) days after counsel's receipt of a copy of the transcript, or such other time period as may be mutually agreed upon by the parties. There shall be no need to re-designate documents used in or exhibits to transcripts which have been previously designated as confidential.

         4. Disputes Concerning Designation(s) Of Confidential Information.

         If any party disputes the designation of any information, document, or testimony as "Confidential, " that party shall attempt to resolve by agreement the question of whether or on what terms the information is entitled to confidential treatment. If the parties are unable to agree as to whether the information is properly designated, counsel for either party may file an appropriate motion with the court. The burden rests upon the person asserting "Confidential" status to demonstrate that the designation is proper. Until a resolution of the dispute is achieved either through consent or order of the court, all persons shall treat the designated information in accordance with its designation.

         5. Qualified Persons To Whom Confidential Information May Be Disclosed.

         Confidential Information may only be disclosed or made available on a need-to-know basis by the party receiving such information to "qualified persons" who are defined to consist of:

a. The United States District Court for the District of Nebraska, including court personnel and members of the jury;
b. The parties named in this Action, including the corporate representative(s) of Defendant (including any of its former and/or current ...

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