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Carrizales v. United States

United States District Court, D. Nebraska

April 28, 2017

NATASHA CARRIZALES, individually and on behalf of NINA CARRIZALES, a Minor, as her guardian and next friend; and NINA CARRIZALES, by and through her mother, guardian and next friend, Natasha Carrizales, Plaintiffs,
v.
UNITED STATES OF AMERICA, Defendant.

          STIPULATED PROTECTIVE ORDER

          Cheryl R. Zwart, United States Magistrate Judge

         Upon a showing of good cause in support of the entry of a protective order to control the discovery and dissemination of confidential or proprietary information in this case (hereafter collectively referred to as “Confidential Information”), IT IS ORDERED THAT:

         1. Confidential Information will include confidential or proprietary business information. For purposes of this Order, the following categories of documents and information will generally be considered “Confidential Information” and subject to this Protective Order:

• Plaintiffs' medical or healthcare records;
• Confidential or proprietary business information

         2. Confidential Information subject to this Protective Order may, depending on the content, be included in a variety of documents, including but not limited to: Agency records, documents produced pursuant to written discovery, answers to interrogatories, responses to requests for admission, deposition testimony, including all copies thereof and other information disclosed in the context of discovery of this case by either party or disclosed pursuant to the discovery procedures created by the Federal Rules of Civil Procedure.

         3. Confidential Information shall not be disclosed or used for any purpose except the preparation and trial of this case, Natasha Carrizales, individually and on behalf of Nina Carrizales, a Minor, as her guardian and next friend, Natasha Carrizales, and Nina Carrizales, by and through her mother, guardian and next friend, Natasha Carrizales - United States District Court of the District of Nebraska - 8:17-CV-19. The parties also understand and agree that Confidential Information may be disclosed and utilized in the preparation and trial of Natasha Carrizales, indiv idually and on behalf of Nina Carrizales, a Minor, as her guardian and nex t friend, Natasha Carrizales, and Nina Carrizales, by and through her mother, guardian and nex t friend, Natasha Carrizales v. Creighton Saint Joseph Regional Healthcare System, LLC, et al. - District Court of Douglas County, Nebrask a - 13-8988.

         4. Confidential Information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:

a. attorneys actively working on this case and attorneys actively working on Plaintiffs' State Court Action - District Court of Douglas County, Nebraska - 13-8988;
b. any person who previously received or authored the materials;
c. persons regularly employed or associated with the attorneys actively working on the case and working on Plaintiffs' State Court Action -District Court of Douglas County, Nebraska - 13-8988;
d. Plaintiffs Natasha Carrizales and Nina Carrizales;
e. treating medical providers, expert witnesses, and consultants retained in connection with this proceeding and Plaintiffs' State Court Action -District Court of Douglas County, Nebraska - 13-8988;
f. mediators, facilitators, or other persons retained by the parties to assist in the resolution of this ...

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