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Hurd v. The City of Lincoln

United States District Court, D. Nebraska

September 29, 2016

TROY M. HURD, Plaintiff,
v.
THE CITY OF LINCOLN, a political subdivision, TOM CASADY, JOHN HUFF, PAT BORER, ROGER BONIN, JEANNE PASHALEK, and LEO BENES, in their individual and official capacities, Defendants.

          TROY HURD, Plaintiff, Kelly K. Brandon AND THE CITY OF LINCOLN, TOM CASADY, JOHN HUFF, PAT BORER, ROGER BONIN, JEANNE PASHALEK and LEO BENES, Defendants

          JEFFERY R. KIRKPATRICK, City Attorney

          STIPULATED PROTECTIVE ORDER

          Cheryl R. Zwart

         1. As used herein:

         a. “Confidential Documents” shall mean documents produced by a party in discovery and designated as “CONFIDENTIAL.” For purposes of this agreement, Confidential Documents shall be limited to following documents under the control of Plaintiff and those documents under the control of the City of Lincoln and not readily available to the general public:

i. Employee personnel and training records;
ii.City of Lincoln policies, procedures, and general orders;
iii. City of Lincoln training records;
iv. Plaintiff's personnel and medical records; and
v. Any other documents or electronic information either Party designates as

         “CONFIDENTIAL.”

         b. “Disclosed” shall mean divulged, revealed, describe d, summarize d, paraphrased, quoted, transmitted or otherwise communicated to any Person or Persons in any manner and for any purpose other than as allowed herein;

         c. “Attorney” shall include all partners, associates, paralegals, secretaries and other employees ...


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