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Starkey v. Amber Enterprises, Inc.

United States District Court, D. Nebraska

November 9, 2017

LANA L. STARKEY, Plaintiff,
v.
AMBER ENTERPRISES, INC., a Corporation; HY-VEE, INC., a Corporation; and MIKE AGOSTINO, Individually; Defendants.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge

         This matter is before the Court on the parties' Joint Stipulation and Motion for Protective Order. (Filing No. 28.) The motion is granted.

         Accordingly, IT IS ORDERED that confidential information and documents received and produced by the parties in this case may be utilized in the preparation of the case, but the parties must do so in accordance with the following terms:

         1. Confidential Information. “Confidential Information” as used herein means private and confidential information pertaining to the parties, and other unpublished and confidential information relating to the parties. Such information may include any type or classification of information which is designated as “Confidential Information” by the supplying party, whether revealed during a deposition, in a document, in an interrogatory answer or otherwise. “Document” as used herein refers to any written, graphic, or electronic information, no matter how produced, recorded, stored or reproduced and includes recordings or other electronically stored data, together with the programming instructions and other written material necessary to understand such recordings and data. In designating information as Confidential Information the supplying party will make such designation only as to that information which that party in good faith believes to be confidential. All documents and every portion thereof designated as confidential shall constitute confidential information for the purposes of this Order and shall be used by the receiving party only for the preparation for and conduct of proceedings herein and not for any business or other purpose whatsoever.

         2. Qualified Recipients. For the purposes of this Order, and subject to the provisions of this paragraph, the persons authorized to receive “Confidential Information” (hereinafter “qualified recipient”) shall include only:

a) The named parties and officers, directors, board members, and in-house legal counsel, of the parties;
b) Legal counsel representing the Defendants and legal counsel representing the Plaintiff, and members of the paralegal, secretarial, or clerical staff who are employed by, retained by, or assisting such counsel;
c) The Court, court reporters who take and transcribe testimony, as well as necessary law clerks and administrative assistants;
d) Consulting or testifying expert witnesses who assist counsel in the preparation of this case;
e) Any mediator retained by the parties in an effort to mediate and/or settle the claims made in this action;
f) Any assistant, paralegal, stenographic, secretarial or clerical personnel employed by, retained by, or assisting a qualified person in this case;
g) Any other persons agreed to by the parties in writing, either as to all or any confidential information in this case.

         Except as provided herein, Confidential Information produced in this case shall be disclosed by the receiving party only to Qualified Persons who shall have read this Protective Order. Provided, however, that nothing herein shall prevent disclosure beyond the terms of this Protective Order if the party claiming confidentiality consents in writing to such disclosure. Requests by a party to disclose Confidential Information which would otherwise be in violation of the terms of this Protective Order shall be made in writing.

         3. Maintenance of Confidentiality. Confidential information shall be maintained confidentially by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, and shall not be disclosed to any person who is not a qualified recipient. Each party, each qualified recipient, and all counsel representing any party, shall use their best efforts to maintain all produced confidential information in such a ...


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