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Kopecky v. Schwan's Home Service, Inc.

United States District Court, D. Nebraska

February 14, 2017

Joseph Kopecky, Plaintiff,
v.
Schwan's Home Service, Inc., Defendant.

          Allison D. Balus, Leigh Campbell Joyce, BAIRD HOLM, LLP, Attorneys for Defendant

          Kathleen Neary, POWERS LAW Attorney for Plaintiff

          JOINT STIPULATED PROTECTIVE ORDER

          Cheryl R. Zwart, United States Magistrate Judge

         WHEREAS, Plaintiff Joseph Kopecky and Defendant Schwan's Home Service, Inc. (individually a "Party" or together the "Parties") hereby agree that either or both may consider certain information, documents, and other items discoverable in the above-captioned matter, pursuant to FED. R. CIV. P. 26(c), to be confidential or proprietary in nature and that such party may seek to protect such items from disclosure, or to designate such items confidential to avoid making such information available to non-disclosed Party representatives, Party employees, non-Parties or the generally public;

         IT IS HEREBY STIPULATED AND AGREED by and between the Parties hereto, through their undersigned counsel, that:

         1. The following definitions shall apply to the Stipulated Protective Order to be issued in this action:

a. "Attorneys" means counsel of record;
b. "Confidential" documents or materials are documents designated pursuant to paragraph 2;
c. "Documents" are all materials or items within the scope of FED. R. CIV. P. 34;
d. "Written Assurance" means an executed document in the form attached as Exhibit A.

         2. Confidential Documents/Material. As used herein, the term "Confidential Material" shall mean "confidential personal financial information and personal bank records, documents, materials, trade secrets, or proprietary information designated by a party in good faith to be confidential." The following information is also considered Confidential Material, if so designated: (1) customer and client names, lists and contact information; (2) employee and owner social security numbers and contact information; (3) employee medical information that may be included in personnel files; and (4) personal information regarding employees not parties to this lawsuit. A Party may designate any document, including interrogatory responses, other discovery responses, documents produced by third parties, or transcripts, to be "Confidential" that it in good faith contends to constitute or contain Confidential Material, confidential information, trade secrets or proprietary information.

         Each Party shall designate such material it deems "Confidential" by marking all documents with the designation "Confidential." In lieu of physically marking a document with the designation "Confidential, " the producing Party can produce (1) written documentation in which it identifies the documents it designates "Confidential" or (2) electronic stored information or documentation in which it includes "Confidential" in the file name of the document.

         Only such portions of a deposition transcript as are affirmatively designated in writing by a Party to be "Confidential" shall be treated as confidential. The Party designating a portion of a deposition transcript as confidential shall either: (1) provide written notice to all Parties by listing the page and inclusive line numbers of the material to be kept confidential, and shall designate such pages confidential; or (2) while on the record at the deposition, verbally designate the portion of the deposition transcript to be kept confidential. In any deposition transcript in which any portion of the transcript has been designated confidential by any Party, the court reporter, or the party holding the original transcript, shall imprint the word "Confidential" on the front page of the original of the deposition transcript. The portion of the deposition transcript containing confidential information shall not be filed with the Court unless it is filed as provided in Paragraph 5 of this Stipulated Protective Order.

         Expert reports and/or summaries containing Confidential Information shall be automatically deemed confidential if the information used to prepare the expert reports and/or summaries included Confidential Materials and/or confidential information. An expert report may avoid a Confidential designation if the expert report avoids specifically referencing Confidential Material or information and/or replaces Confidential Material ...


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