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Muratella v. National Rural Electric Cooperative Association

United States District Court, D. Nebraska

July 20, 2017

CORRINA J. MURATELLA, Plaintiff,
v.
NATIONAL RURAL ELECTRIC COOPERATIVE ASSOCIATION, Defendant.

          JOINT STIPULATED PROTECTIVE ORDER

          Cheryl R. Zwart, United States Magistrate Judge

         The Parties in this action agree, and it is hereby ordered, that this Protective Order shall govern the use and dissemination of all information, documents, or materials that are produced by the parties and designated as Confidential.

         1. DEFINITIONS.

         Limitations under this Protective Order on the use or disclosure of documents, deposition testimony or other discovery designated as "Confidential" shall apply to

(a) all information, copies, extracts and complete or partial summaries prepared or derived from such documents, testimony or other discovery;
(b) portions of deposition transcripts, answers to interrogatories, responses to requests for admissions, responses to requests for production, initial disclosures and exhibits thereto which directly refer or directly relate to any such information, documents, copies, extracts or summaries; and
(c) portions of briefs, memoranda or any other writing filed with the Court and exhibits thereto which directly relate to any such information, documents, copies, extracts or summaries.

         2. CONFIDENTIAL DOCUMENTS.

         Before produced documents are copied or inspected, the producing party may stamp as "Confidential" any document or deposition testimony it believes contains confidential or proprietary business information and/or trade secrets in order to limit disclosure as set forth in this Paragraph 2. Documents may also be designated as "Confidential" by written notice to opposing counsel which identifies the documents so designated by Bates number. Deposition testimony must be designated as “Confidential” by specific line and page number within 30 days of the deposition. The failure to designate information in accordance with this Protective Order shall not preclude subsequent designation of such information as Confidential, provided that no party is materially disadvantaged by such subsequent designation. Documents designated "Confidential, " deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any purpose other than this litigation and will not be disclosed except pursuant to court order entered after notice to anyone except:

(a) Counsel who have signed this Order approving it as to form and content; attorneys who are employed or are members of the law firms of counsel who have signed this Order; Defendant's in house counsel; Defendant's key management personnel; law clerks, secretaries or paralegals directly involved in the conduct of this litigation;
(b) Experts and consultants retained by either of the parties or their counsel for purposes of assisting in the preparation or presentation of claims or defenses;
(c) Any deposition or trial witness, during the course of deposition or trial testimony or in preparation for such testimony, when necessary to the testimony or preparation of such witness;
(d) Any person who was involved in the preparation of the document;
(e) The Court, Court personnel, court reporters and similar ...

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