United States District Court, D. Nebraska
DANIEL J. KOTTAS, Plaintiff,
UNITED STATES OF AMERICA, Defendant.
STIPULATED PROTECTIVE ORDER
R. Zwart United States Magistrate Judge.
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:
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.
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.
Confidential Information shall not be disclosed or used for
any purpose except the preparation and trial of this case,
Daniel J. Kottas v. United States of America, and
will not be used in any other litigation.
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
c. persons regularly employed or associated with the
attorneys actively working on the case;
d. Plaintiff Daniel J. Kottas;
e. treating medical providers, expert witnesses, and
consultants retained in connection with this proceeding;
f. mediators, facilitators, or other persons retained by the
parties to assist in the resolution of this ...