United States District Court, D. Nebraska
MATT D. WATKINS, an individual, Plaintiff,
OTOE COUNTY, NEBRASKA, a political subdivision of the STATE OF NEBRASKA, Defendant.
STIPULATED PROTECTIVE ORDER
Gossett, III United States Magistrate Judge.
matter comes before the Court on the parties' Joint
Stipulation for Entry of Protective Order (Filing No. 27).
The Court approves the stipulation. Accordingly, the Court
enters the following Stipulated Protective Order:
this action, the parties have sought and are seeking through
discovery information which is confidential and proprietary
in nature. In addition, the parties anticipate there will be
questioning concerning confidential information in the course
parties agree that the release or disclosure of the
Confidential Information outside the scope of this litigation
would harm the business interests, otherwise embarrass, or
invade the privacy of the designating party.
parties jointly stipulate to and request the entry of a
Protective Order to prevent the disclosure and use of
Confidential Information by any party or non-party except as
set forth herein.
Under the terms of this Protective Order, “Confidential
Information” shall include, but not be limited to, any
document, file, electronic material, portions of files,
transcribed testimony or responses to discovery requests,
including any extract, abstract, chart, summary, note or copy
made therefrom containing or comprising:
a. Documents and information pertaining to individuals,
including Plaintiff, that were or are employed by Defendant
or a non-party;
b. Plaintiff's and/or Defendant's financial
c. Information related to the medical care and treatment of
Protective Order applies to Confidential Information produced
by Plaintiff, Defendant, and any non-party who produces
documents as a result of discovery subpoenas or other
requests, including, but not limited to, information or
materials already produced.
Protective Order applies to the parties and all attorneys and
the law firms representing any party in this case.
Where any kind of Confidential Information is produced,
provided or otherwise disclosed by a party or a non-party in
response to any discovery request or subpoena, such
Confidential Information should be designated as such by
stamping “CONFIDENTIAL” on the documents that
will be covered by this Protective Order, and such stamp
shall be preserved on the copies of such documents,
including, but not limited to, pages of any deposition
transcript or exhibit which discloses or discusses the
protected information. Such documents, information or
materials may be designated as Confidential only if they are
not otherwise publicly available.
Protective Order shall be without prejudice to the right of
any of the parties to this action (i) to seek any further
Protective Order; or (ii) by application and notice, to seek
relief from any provision of the Protective Order
contemplated hereby on any ground. During the pendency of any
challenge to the applicability of this Protective Order to
any document, information or thing, ...