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MMW Partners, LLC v. Western Agricultural Insurance Co.
United States District Court, D. Nebraska
November 27, 2017
MMW PARTNERS, LLC, Plaintiff,
WESTERN AGRICULTURAL INSURANCE COMPANY D/B/A FARM BUREAU PROPERTY & CASUALTY INSURANCE COMPANY, Defendant.
M. Bazis, United States Magistrate Judge
to the Order entered in this case (Filing No. 26), a
protective order is entered as follows:
Defendant anticipates that documents or information may be
requested in this matter which contains or consists of
valuable trade secrets and other proprietary or personal
information (hereafter “Confidential
Information”). Any documents produced or information
provided by Defendant pursuant to or in response to any
discovery request may be designated by Defendant as
“confidential” in the following manners:
a. By physically imprinting the words “8:17-CV-159:
CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER” by Bates
stamp or watermark on every page of any document produced.
b. By physically electronically imprinting the words
“8:17-CV-159: CONFIDENTIAL AND SUBJECT TO PROTECTIVE
ORDER” by Bates stamp or watermark on every page of any
c. By imprinting the words “8:17-CV-159: CONFIDENTIAL
AND SUBJECT TO PROTECTIVE ORDER” next to or above any
Answer to any Interrogatory or any other written discovery
d. With respect to portions of a deposition transcript, by
making arrangements with the attending court reporter to bind
the confidential portion(s) of such transcripts separately
and label them as “CONFIDENTIAL AND SUBJECT TO
PROTECTIVE ORDER.” e. Such portions of any deposition
transcript that are to be designated as confidential, shall
but designated as such on the record when possible, but a
party may also designate portions of the deposition within
thirty (30) days after the date of final transcription.
documents and information provided by Defendant in response
to a discovery request or deposition testimony designated as
“confidential” shall be subject to the following
a. Such documents or information shall be used only for the
purpose of the litigation in this matter and not for any
business or other purposes.
b. Such documents or information shall not be communicated or
disclosed in any manner, either directly or indirectly, to
anyone other than:
i. The attorneys of record and persons employed by them,
including court reporters and/or vendors the attorneys
utilize for litigation support; ii. Outside experts who have,
prior to disclosure, agreed to be bound by the terms of this
Protective Order; iii. Plaintiff or Defendant and their
officers, employees, or agents, including insurers, who need
to be informed for purposes of this litigation; iv. The Court
and Court personnel; and v. Such other persons as the Court
may specifically approve after notice and hearing.
c. That all information designated as
“confidential” in whatever format shall be
furnished only under the terms of this Protective Order and
shall be treated by all persons accorded access pursuant to
this Protective Order as constituting Confidential
Information and shall neither be used nor disclosed except
for the purpose of this litigation, and solely in accordance
with this Protective Order or subsequent Order of the Court.
d. No Confidential Information shall be further disclosed to
anyone except those categories of persons provided herein who
have signed a Nondisclosure Agreement in the form attached
hereto and to whom disclosure is necessary for the purposes
associated with this lawsuit. The parties' counsel of
record, and other persons or entities retained to assist in
this lawsuit who have signed a Nondisclosure Agreement, shall
appropriately notify such persons or entities that the
disclosure is made in confidence and must be kept in
confidence in accordance with this Protective Order.
e. Individuals authorized to review Confidential Information
pursuant to this Protective Order shall hold such information
in the strictest confidence and shall not divulge the
information, either verbally or in writing, to any other
person, entity, or ...
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