United States District Court, D. Nebraska
RODOLFO A. QUILES, Plaintiff,
UNION PACIFIC RAILROAD COMPANY; RODNEY N. DOERR; EDWARD ADELMAN; TRACY SCOTT; and KATHLEEN HUGHES, Defendants.
M. BAZIS, UNITED STATES MAGISTRATE JUDGE.
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.
IT IS ORDERED as follows:
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.
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.
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
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
e. The Court, Court personnel, court reporters and similar