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Millard Gutter Co. v. State Farm Fire and Casualty Co.

United States District Court, D. Nebraska

March 3, 2017

MILLARD GUTTER COMPANY, a Corporation d/b/a MILLARD ROOFING AND GUTTER, Plaintiff,
v.
STATE FARM FIRE AND CASUALTY COMPANY a/k/a STATE FARM INSURANCE COMPANY a/k/a STATE FARM, Defendant.

          STIPULATED PROTECTIVE ORDER

          F.A. Gossett, III, United States Magistrate Judge

         THIS MATTER comes on before the Court upon the stipulation of the parties for the entry of this Protective Order. Upon consideration thereof, the Court hereby ORDERS as follows:

         1. The parties anticipate that documents or information may be requested in this matter which contain or consist of valuable trade secrets, other proprietary information or personal information (hereinafter, "Confidential Information"). Any documents produced or information provided by a party pursuant to or in response to any discovery request may be designated by either party as "confidential" in the following manners:

a. By imprinting the word "confidential" on the first page, footer, cover sheet, or in the electronic file name of any document produced.
b. By imprinting the word "confidential" next to or above any Answer to any Interrogatory or any other written discovery response.
c. With respect to portions of a deposition transcript, by making arrangements with the attending court reporter to bind the confidential portion(s) of such transcripts separately and labeling them as "confidential."

         2. All documents and information provided by a party in response to a discovery request or deposition testimony designated as "confidential" shall be subject to the following restrictions:

a. Such documents or information shall be used only for the purpose of this litigation and not for any business or other purposes whatsoever.
b. Such documents or information shall not be communicated or disclosed in any manner, either directly or indirectly, to anyone other than:
(1) The attorneys of record and persons employed by them;
(2) Outside experts who have, prior to disclosure, agreed to be bound by the terms of this Protective Order;
(3) Plaintiff or Defendant and their officers, employees, or agents, including insurers, who have a need to know for purposes of this litigation;
(4) This Court and Court personnel; and
(5) Such other persons as the Court may specifically approve after ...

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