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Boyd Jones Construction Co. v. Velinsky

United States District Court, D. Nebraska

September 20, 2017

BOYD JONES CONSTRUCTION COMPANY, Plaintiff,
v.
BENJAMIN VELINSKY, Defendant.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         This matter is before the Court on the parties' Joint Motion for Protective Order and Order Governing the Disclosure of Privileged Information. (Filing No. 31.) The motion is granted.

         IT IS ORDERED:

         This Protective Order shall govern the use and dissemination of all information, documents, or materials produced by the parties and designated as Confidential.

         A. 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 or testimony; (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. Such Confidential Information shall include the following:

i. Any and all documents referring or related to confidential and/or proprietary human resources or business information, including Trade Secrets;
ii. Client/customer contact and preference information;
iii. Documents identifying potential clients/customers or potential projects;
iv. Any financial information pertaining to either party;
v. Compensation of Plaintiff's current or former personnel;
vi. Any documents from the personnel, medical, FMLA, or workers' compensation file of any current or former employee or contractor; and
vii. Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits.

         Nothing in this Protective Order, including the list of Confidential Information above, should be construed as a waiver of any objections to particular discovery requests or a concession of the relevance or admissibility of any document or information.

         B. 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 Information in order to limit disclosure as set forth in this Paragraph B. Documents designated “Confidential, ” deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any ...


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