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Quiles v. Union Pacific Railroad Company

United States District Court, D. Nebraska

November 1, 2017

RODOLFO A. QUILES, Plaintiff,
v.
UNION PACIFIC RAILROAD COMPANY; RODNEY N. DOERR; EDWARD ADELMAN; TRACY SCOTT; and KATHLEEN HUGHES, Defendants.

          PROTECTIVE ORDER

          SUSAN M. BAZIS, UNITED STATES MAGISTRATE JUDGE.

         This matter is before the Court on the Joint Motion for Entry of Protective Order. (Filing No. 114.) Having considered the matter, the motion is granted.

         Accordingly, IT IS ORDERED as follows:

         1. SCOPE.

         This Order shall govern all documents produced by the parties in the course of discovery, including initial disclosures, all responses to discovery requests, all deposition testimony and exhibits, other materials which may be subject to restrictions on disclosure for good cause, and information derived directly therefrom (collectively “documents”), shall be subject to this Order concerning confidential information as set forth below.

         2. CONFIDENTIAL DOCUMENTS/INFORMATION.

         The parties seek to protect from disclosure certain personal and sensitive information regarding the employees of Union Pacific Railroad Company relating to this lawsuit and Plaintiff's personal and confidential information. Before produced documents are copied or inspected, the producing party may stamp as "Confidential- Subject to Protective Order" or similar notation on any document or deposition testimony which contains such sensitive information. Documents may also be designated as "Confidential- Subject to Protective Order" or similar notation by written notice to opposing counsel which identifies the documents so designated by Bates number.

         Documents designated "Confidential- Subject to Protective Order" or similar notation, deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any purpose other than 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 by Plaintiff, co-counsel, retained outside counsel, in house counsel, law clerks, secretaries or paralegals directly involved in the conduct of this litigation;
b. Experts and consultants retained by a party to this action 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, when necessary to the testimony 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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