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Norfolk Transmission & Muffler Service, Inc. v. Owners Insurance Co.

United States District Court, D. Nebraska

September 12, 2017

NORFOLK TRANSMISSION & MUFFLER SERVICE, INC., Plaintiff,
v.
OWNERS INSURANCE COMPANY, Defendant.

          PROTECTIVE ORDER

          Susan M. Bazis, United States Magistrate Court Judge

         Pursuant to the parties' Joint Stipulation for Entry of Protective Order (Filing No. 43), IT IS HEREBY ORDERED as follows:

         1. Defendant anticipates that documents or information may be requested in this matter which contains or consists of valuable trade secrets and other proprietary or personal information (hereafter “Confidential Information”). Any documents produced or information provided by Defendant pursuant to or in response to any discovery request may be designated by Defendant as “confidential” in the following manners:

a. By physically imprinting the words “8:16-CV-489: CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER” by Bates stamp or watermark on every page of any document produced.
b. By physically electronically imprinting the words “8:16-CV-489: CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER” by Bates stamp or watermark on every page of any document produced.
c. By imprinting the words “8:16-CV-489: CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER” next to or above any Answer to any Interrogatory or any other written discovery response.
d. With respect to portions of a deposition transcript, by making arrangements with the attending court reporter to bind the confidential portion(s) of such transcripts separately and label them as “CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER.”
e. Such portions of any deposition transcript that are to be designated as confidential, shall but designated as such on the record when possible, but a party may also designate portions of the deposition within thirty (30) days after the date of final transcription.

         2. All documents and information provided by Defendant in response to a discovery request or deposition testimony designated as “confidential” shall be subject to the following restrictions:

a. Such documents or information shall be used only for the purpose of the litigation in this matter and not for any business or other purposes.
b. Such documents or information shall not be communicated or disclosed in any manner, either directly or indirectly, to anyone other than:
i. The attorneys of record and persons employed by them, including court reporters and/or vendors the attorneys utilize for litigation support;
ii. Outside experts who have, prior to disclosure, agreed to be bound by the terms of this Protective Order;
iii. Plaintiff or Defendant and their officers, employees, or agents, including insurers, who need to be informed for ...

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