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Michalski v. Cargill, Inc.

United States District Court, D. Nebraska

May 15, 2017

VAUGHN L. MICHALSKI, Plaintiff,
v.
CARGILL INCORPORATED, DOUGLAS COUNTY, NEBRASKA, A Delaware Corporation, Defendant.

          AGREED PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge

         Pursuant to Federal Rule of Civil Procedure 26(c), the parties have agreed to this Protective Order to facilitate document production and other discovery efforts under the Federal Rules of Civil Procedure, because confidential personal, personnel, and/or business information is likely to be disclosed or produced during the course of discovery in this litigation.

         To protect the respective interests of the parties and to facilitate the progress of discovery in this case, IT IS ORDERED THAT:

         1. The term “CONFIDENTIAL Information” as used herein shall mean any document, testimony, answers to interrogatories, or thing that is designated by a party as “CONFIDENTIAL” as provided in this Protective Order.

         2. The parties agree that any party hereto may reasonably and in good faith designate documents or written discovery responses as CONFIDENTIAL Information:

(a) In the case of documents produced or written discovery responses, by stamping the documents “CONFIDENTIAL” or by giving written notice to the other party within thirty (30) calendar days after production of the documents.
(b) In the case of deposition testimony or deposition exhibits, by making the designation on the record during the deposition or by giving written notice to the other party within thirty (30) calendar days after receiving the transcript of the deposition.
(c) In the case of electronic media, by labeling the outside of the media or enclosure as CONFIDENTIAL or by designating individual files within electronic media as CONFIDENTIAL or by giving written notice to the other party within thirty (30) calendar days after production of the electronic media.
(d) In the case of documents produced or deposition testimony given prior to the execution of this Protective Order, by designating such records or testimony as CONFIDENTIAL by one of the methods above within thirty (30) days after the mutual execution of this Protective Order.
(e) A party may designate documents, electronic media or deposition testimony as CONFIDENTIAL after the time periods set forth herein if the failure to timely designate those documents was inadvertent or the result of excusable neglect and the receiving party is not prejudiced thereby.

         3. At any time after the delivery of CONFIDENTIAL Information, counsel for the party or parties receiving the materials may challenge the CONFIDENTIAL designation of all or any portion thereof by providing written notice of such challenge to counsel for the party disclosing or producing the materials. Such written notice must be served within thirty (30) days after the materials have been designated as CONFIDENTIAL and must identify specifically the documents or testimony being challenged and the basis for challenging the CONFIDENTIAL designation.

(a) In accordance with Federal Rule of Civil Procedure 26(c)(1), the parties shall in good faith confer with each other in an effort to resolve the dispute without court involvement.
(b) If the parties are unable to agree as to whether the CONFIDENTIAL designation of discovery material is appropriate, the party or parties receiving the CONFIDENTIAL Information shall certify to the Court that the parties cannot reach an agreement as to the CONFIDENTIAL nature of all or a portion of the documents. Thereafter, the party or parties disclosing or producing the CONFIDENTIAL Information shall have fifteen (15) days from the date of certification to file a motion for protective order with regard to any CONFIDENTIAL Information in dispute.
(c) The party or parties producing the CONFIDENTIAL Information shall have the burden of establishing that the disputed documents are entitled to CONFIDENTIAL treatment. If the party or parties producing the CONFIDENTIAL Information do not timely file a motion for protective order, then the documents in dispute ...

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