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Ideus v. Teva Pharmaceuticals USA, Inc.

United States District Court, D. Nebraska

February 15, 2017

Stephanie Ideus Plaintiff,
v.
Teva Pharmaceuticals USA, Inc., and Teva Women's Health, Inc., Defendants.

          PROPOSED PROTECTIVE ORDER

          CHERYL R. ZWART UNITED STATES MAGISTRATE JUDGE.

         This Order allows the parties to this action to designate certain documents produced in discovery - for example, documents containing trade secrets or other proprietary and confidential research, development, or commercial information, or documents containing confidential personal information, including information deemed confidential by operation of the Code of Federal Regulations, such as information identifying anyone who reports an alleged adverse drug reaction or anyone who allegedly experienced an adverse drug reaction - as confidential and subject to an enhanced level of protection from disclosure. This Order strikes an appropriate balance between the parties' interests in prosecuting and defending this case, the judicial interest in the efficiency and integrity of the discovery process, and the public interest in access to information. Therefore, due notice having been given, and the Court being duly advised in the premises, the Court enters the following Order:

1. When used in this Order, the following words shall have the following meanings:
“Documents” means (1) all written, recorded or graphic matter whatsoever and information produced on computer disks or tapes, including all written materials, and (2) any copies, reproductions or summaries of the foregoing, including microfilmed, imaged or electronic copies.
“Discovery Materials” means (1) documents or other information produced by any party or third person, whether pursuant to the applicable civil rules, by subpoena or by agreement, other than documents that are publicly available; (2) interrogatory or other discovery responses; and (3) deposition testimony of any party or third person taken in this action, exhibits thereto and/or any videos or transcripts thereof, whether in written or computer format, and all contents of the foregoing.
“Producing Party” means any party or third person producing discovery materials, whether pursuant to the applicable civil rules, by subpoena, or by agreement.
“Receiving Party” means any party receiving discovery materials from a producing party, whether pursuant to the applicable civil rules, by subpoena, or by agreement.
“Disclose” (and any variant thereof) means to show, give, make available, reproduce, or communicate any discovery materials, or any part or content thereof.
“Confidential Discovery Materials” means any discovery materials that are designated in good faith as “Confidential” by any party or third person. Confidential Discovery Materials are those materials that constitute or contain personal medical information or other personal information pertaining to research subjects or patients, reporters of alleged adverse drug events or persons or entities identified in such reports; trade secrets or other confidential research, development, or commercial information which may include proprietary information such as costs, pricing, budgets, customer lists and data, distributor lists and agreements, personnel files, and other private and personal information relating to employees; product formulations, manufacturing procedures and standards, financial data, identity of suppliers, identity of manufacturers, trade secrets, consumer data, confidential research, business plans, strategies and data, marketing plans and strategies, and any other confidential or proprietary information.
“Attorneys of Record” means attorneys of record for any of the parties to this action, members of the firm of the attorneys of record for the parties, and any in-house attorneys who are employed by the parties.
2. Any Confidential Discovery Materials produced by the producing party and designated as such shall be used solely for the purposes of this litigation and shall not be used for any other legal action, except by agreement of the parties or subject to a Court Order.
3. Disclosure of Confidential Discovery Materials other than in accordance with the terms of this Order may subject the disclosing party to such sanctions and remedies as the Court may deem appropriate.
4. Subject to the terms, conditions, and restrictions of this Order, Confidential Discovery Materials marked “Confidential” may be disclosed only to the following persons and only to the extent such persons have a legitimate need to know the ...

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