Searching over 5,500,000 cases.

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Rasmussen Air & Gas Energy, Inc. v. Ingersoll-Rand Co.

United States District Court, D. Nebraska

September 8, 2017




         This matter is before the Court on the Unopposed Motion for Amended Protective Order. (Filing No. 83.) The motion is granted.


         Scope and Definitions

         1. This Amended Protective Order applies to all information, documents, testimony and things subject to discovery in this action which contain non-public, confidential information or trade secrets designated as Protected Material pursuant to the terms of this Order, as well as any secondary material, such as pleadings, written discovery, expert reports, notes, summaries or any other materials that contain, describe or reflect such information (collectively referred to herein as “Protected Materials”).

         2. Protected Material may be designated by any Producing Party as:

         (a) “CONFIDENTIAL” if it (i) contains non-public, commercially-sensitive information (e.g. unpublished advertising, web pages, signage, logos and the like); (ii) contains technical, financial and/or other business information (e.g. pricing, customer lists, business and/or marketing plans or analysis, license agreements and the like), the public disclosure of which would cause competitive harm to the Producing Party; (iii) is subject to an express obligation of confidentiality owed by the Producing Party to a third party; (iv) contains personally identifiable information about an individual as described in NECivR 5.3(b)(1)-(5); or (v) constitutes a trade secret under the laws of the State of Nebraska.

         (b) “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” if it contains CONFIDENTIAL information under Paragraph 2(a), the disclosure of which to a Receiving Party, as opposed to a third party, would cause competitive harm to the Producing Party.

         3. As used herein, “Producing Party” shall refer to any party to this action, or to any third party (whether voluntarily or pursuant to subpoena) who discloses, testifies, produces or makes available for inspection any Protected Material.

         4. “Receiving Party” shall refer to any person who receives Protected Material from a Producing Party.

         Permitted Disclosure and Use of Protected Material

         5. Protected Material shall not be distributed, disclosed or made available to anyone except as expressly provided in this Order.

         6. Protected Material shall be used solely for this litigation and any related appeals and shall not be used for any other purpose whatsoever, including without limitation any other litigation or any business or competitive purpose or function of any kind.

         Persons Who May Access Protected Material

         7. “Confidential” Material. Only the following individuals shall have access to materials designated “CONFIDENTIAL, ” absent the express written consent of the Producing Party or further court order:

         (a) Up to four (4) corporate representatives of the Receiving Party who have complied with Paragraph 9;

         (b) Outside counsel of record for the parties to this action, including any attorneys, paralegals, technology specialists and clerical employees of their respective law firms assisting in the litigation;

         (c) Outside experts and consultants of the Receiving Party, who have complied with the procedures of Paragraph 10, and their support staff and clerical employees assisting in the litigation;

         (d) The Court, court personnel, the jury, court reporters and/or videographers who record testimony or other proceedings in this action;

         (e) Professional litigation support vendors, including copy, graphics, translation, database, trial support and/or trial consulting services (“Professional Vendor”), who shall be provided a copy of this Amended Protective Order and execute Exhibit A, and mock jurors hired by trial consultants but only in accordance with Paragraph 11 below; and

         (f) While testifying at deposition, hearings, or trial in this action only: (i) any current or former officer, director or employee of the Producing Party or original source of the information; (ii) any person designated by the Producing Party to provide testimony pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure; and (iii) any person who authored, previously received or was directly involved in the specific matter(s) addressed in the Protected Material, as evident from its face or reasonably certain in view of other testimony or evidence. Persons authorized ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.