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Hunt v. Johns

United States District Court, D. Nebraska

July 13, 2017

LARRY HUNT, Plaintiff,
v.
RON JOHNS AS AN INDIVIDUAL AND IN HIS CAPACITY AS DIRECTOR OF THE SCOTTS BLUFF COUNTY DETENTION CENTER, and SCOTTS BLUFF COUNTY, and MONUMENT VISION, PC, and OREGON TRAIL EYE CENTER, PC, and JOHN DOES 1-99, Defendants.

          STIPULATED PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         This matter is before the Court on the parties' Motion for Protection Order. (Filing No. 26.) The motion is granted.

         Accordingly, IT IS ORDERED:

         1) This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, video files, audio files, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. It will not apply to any documents, or information, produced prior to the execution of this agreement unless a party designates such documents or information in accordance with and pursuant to the terms of this Order. Upon any such designation, this Order shall apply to all such documents or information so designated from the date of designation forward.

         2) As used in this Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.

         3) Information designated “CONFIDENTIAL” shall be information that is confidential and implicates common law and statutory privacy interests of any party or third party to these proceedings. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case. Third-parties disclosing any CONFIDENTIAL information may designate such CONFIDENTIAL information as CONFIDENTIAL per this Protective Order and any party to this Protective Order may designate CONFIDENTIAL information produced by a third-party as CONFIDENTIAL per this Protective Order.

         4) CONFIDENTIAL documents, materials, and/or information (collectively “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 their staff engaged in day-today legal or clerical work on this case;
b) persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case;
c) the parties;
d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
e) the Court and its employees (“Court Personnel”);
f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
g) persons whom counsel reasonably believes to be the authors, senders, addressees, and/or copy recipients of such CONFIDENTIAL information, current management-level employees of the parties, or any other person with actual knowledge of the information contained therein so long as: (i) those persons have been identified in Fed.R.Civ.P. 26(a) disclosures (or amendments thereto); and (ii) ...

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