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Trahan v. Omaha Public Schools

United States District Court, D. Nebraska

November 13, 2017

NIKISHA TRAHAN, Plaintiff,
v.
OMAHA PUBLIC SCHOOLS, a political subdivision of the City of Omaha, Nebraska, Defendant.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         This matter is before the Court on the parties' Joint Motion for Stipulated Protective Order. (Filing No. 7.) The motion is granted.

         Accordingly, IT IS ORDERED as follows:

         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. Documents referring or related to confidential and proprietary human resources or business information; financial records of the parties; compensation of Defendant's current or former personnel; policies, procedures and/or training materials of Defendant; and/or Defendant's organizational structure;
ii. Documents from the personnel, medical, FMLA, or workers' compensation file of any current or former employee or contractor;
iii. Documents relating to the Plaintiff's medical and/or health benefits information or that of any of Defendant's other customers or employees;
iv. Portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits and designated as Confidential.

         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 or proprietary business information and/or trade secrets in order to limit disclosure as set forth in this Paragraph B. Documents may also be designated as "Confidential" by written notice to opposing counsel which identifies the documents so designated by Bates number. Documents designated "Confidential, " deposition testimony so designated, and information derived therefrom will be retained by producing counsel and will not be used for any purpose other than this litigation and will not be disclosed except pursuant to Court order entered after notice, to anyone except:

i. Counsel who have signed this Order approving it as to form and content, attorneys who are employed or are members of the law firms of counsel who have signed this Order, retained outside counsel, in-house counsel, law clerks, secretaries, or paralegals directly involved in this litigation;
ii. Experts and consultants retained by either of the parties for purposes of assisting in the preparation or presentation of claims or defenses;
iii. Any deposition or trial witness, during the course of deposition or trial testimony, when necessary to the testimony of such witness, or during preparation ...

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