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Evanston Insurance Co. v. Prime Time Healthcare LLC

United States District Court, D. Nebraska

December 14, 2016

EVANSTON INSURANCE COMPANY, Plaintiff,
v.
PRIME TIME HEALTHCARE LLC, Defendant/Third-Party Plaintiff,
v.
ROBERT RENSING AGENCY, INC. d/b/a RENSING INSURANCE and JEFFREY W. BROWN Third-Party Defendants.

          EVANSTON INSURANCE COMPANY, Plaintiff Tory M. Bishop # 18527 Jeremy Fitzpatrick # 21943 KUTAK ROCK LLP

          PRIME TIME HEALTH CARE, LLC, Defendant Jill R. Ackerman, #17623 Nicholas K. Rudman, #25182 BAIRD HOLM LLP

          ROBERT BROWN AGENCY, INC. d/b/a RENSING INSURANCE and JEFFREY W. BROWN, Third Party Defendants Patrick G. Vipond, #16390 Sarah M. Dempsey, #25107 LAMSON DUGAN & MURRAY LLP

          STIPULATED PROTECTIVE ORDER

          Thomas D. Thalken U.S. Magistrate Judge

         The parties, by and through their respective undersigned counsel, hereby stipulate to and request the entry of the following Protective Order in order to expedite the flow of discovery, facilitate the resolution of disputes over claims of confidentiality and provide adequate protection for material deemed confidential.

         IT IS HEREBY ORDERED THAT:

         1. The term “Confidential Information” as used herein shall mean any document, testimony, answers to interrogatories, or thing that is designated by a party as “CONFIDENTIAL” as provided in this Protective Order.

         2. The parties agree that any party hereto may reasonably and in good faith designate any documents, disc or other electronic media, or written discovery responses as Confidential Information which in good faith it believes contains confidential or proprietary personal or business information and/or trade secrets:

(a) In the case of documents produced or written discovery responses, by stamping the documents “CONFIDENTIAL” or by giving written notice with reference to applicable Bates numbers to the other party at the time of production or within thirty (30) calendar days after production of the documents.
(b) In the case of deposition testimony or deposition exhibits, by making the designation on the record during the deposition or by giving written notice to the other party within thirty (30) calendar days after receiving the transcript of the deposition. Each reporter participating in any such deposition shall be informed about and provided with a copy of this Protective order and shall agree to be bound by its terms. Each such reporter shall designate the portions of deposition transcripts designated as “Confidential” with the legend “Confidential-Designated by Counsel.”
(c) In the case of electronic media, by labeling the outside of the media or enclosure as CONFIDENTIAL or by designating individual files within electronic media as CONFIDENTIAL or by giving written notice to the other party at the time of production or within thirty (30) calendar days after production of the electronic media.
(d) In the case of documents produced or deposition testimony given prior to the execution of this Protective Order, by designating such records or testimony as CONFIDENTIAL by one of the methods above within thirty (30) days after the mutual execution of this Protective Order.
(e) A party may designate documents, electronic media or deposition testimony as CONFIDENTIAL after the time periods set forth herein if the failure to timely designate those documents was inadvertent or the result of excusable neglect.

         3. At any time after the delivery of Confidential Information, counsel for the party or parties receiving the materials may challenge the CONFIDENTIAL designation of all or any portion thereof by providing written notice of such challenge to counsel for the party disclosing or producing the materials. Such written notice must specifically identify the documents or testimony being challenged and the basis for challenging the CONFIDENTIAL designation. If the parties are unable to agree as to whether the CONFIDENTIAL designation of discovery material is appropriate, a party challenging the designation may make an appropriate motion to the Court, providing the designating party not less than ten (10) days' notice before moving for an ...


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