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Weis v. Triage Staffing, Inc.

United States District Court, D. Nebraska

January 26, 2017

AMY WEIS, Plaintiff,
v.
TRIAGE STAFFING, INC., Defendant.

          AMY WEIS, Plaintiff Bonnie M. Boryca, ERICKSON SEDERSTROM, P.C. Plaintiff's Attorneys

          TRIAGE STAFFING, INC., Defendant, Larry E. Welch, Damien J. Wright, Welch Law Firm, P.C., Defendant's Attorneys

          JOINT MOTION AND STIPULATION FOR PROTECTIVE ORDER

          Cheryl R. Zwart United States Magistrate Judge.

         WHEREAS, the parties to this proceeding, Amy Weis and Triage Staffing, Inc., (referred to herein individually as “Party, ” or collectively as “Parties”), wish to protect certain confidential documents and information from public dissemination and agree to prevent such dissemination pursuant to the terms of the following Stipulation for Protective Order and jointly move the Court for approval of this stipulation; The Parties anticipate that there may be produced a party's confidential and sensitive personal and medical information (hereinafter, collectively referred to as "Confidential Information").

         WHEREAS Confidential Information should not be released into the public domain, but rather should be treated as confidential pursuant to the privacy interests of the Parties; WHEREAS Confidential Information should also not be released to Triage Staffing, Inc. itself or any of its employees or owners, to protect the privacy of Amy Weis; WHEREAS the Parties, through counsel, have agreed to be bound by this Stipulation for Protective Order and consent to the entry of this Stipulation for Protective Order to prevent unnecessary disclosure or dissemination of Confidential Information to anyone but counsel of record in this matter and consultants or expert witnesses who agree to and execute the attached Exhibit A, agreeing to be bound by the terms of this stipulation.

         IT IS HEREBY STIPULATED TO, AGREED AND ORDERED that the terms and conditions of this Stipulation for Protective Order shall govern the handling of the documents and other information produced by any Party:

         1. This Stipulation for Protective Order is entered for the purposes of this case and shall remain in full force and effect unless modified by an Order of this Court. Without limiting the foregoing, this Stipulation for Protective Order shall survive and remain in full force and effect after the termination of this litigation.

         2. This Stipulation for Protective Order shall be effective between the parties immediately upon signing and filing it with the United States District Court for the District of Nebraska.

         3. Nothing in this Stipulation for Protective Order shall limit or preclude the Parties from applying to the Court to modify the terms herein, or for further or additional protective orders as the Court may deem appropriate.

         4. When used in this Stipulation for Protective Order, the word "documents" means all written, recorded, graphic, or electronically stored information whatsoever including, but not limited to, documents produced by a producing Party to this action whether pursuant to Nebraska Rules of Civil Discovery, a subpoena, or by agreement.

         5. For purposes of this Stipulation for Protective Order, the term “Party” includes a Party's agents, attorneys, directors, employees, members, officers and partners.

         6. Portions of documents and materials produced or provided by any Party and that are marked “CONFIDENTIAL-ATTORNEY EYES ONLY” shall be considered confidential material so long as such materials fall within the above definition of “Confidential Information”. The producing Party shall designate clearly on any document or other material produced that its contents should be confidential, by labeling or identifying each document or other material as “CONFIDENTIAL-ATTORNEY EYES ONLY.” 7. All documents requested by and/or produced in response to a subpoena to a non-party or otherwise produced by a non-party shall be presumed to be Confidential Information pursuant to this Stipulation for Protective Order and treated as such, unless otherwise ordered by the Court or agreed to by the Parties and the non-party producing such documents. The presumption expires after 14 days from when the Parties receive the non-party's production unless within that time period a Party or the non-party producing the documents designates the documents “CONFIDENTIAL-ATTORNEY EYES ONLY” pursuant to this Stipulation for Protective Order.

         8. Documents labeled or identified as “CONFIDENTIAL-ATTORNEY EYES ONLY” shall be revealed only to and used by:

a. This Court and its staff/personnel (offered under seal or as restricted-access documents pursuant to the ...

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