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KD v. Douglas County Public School District No. 001

United States District Court, D. Nebraska

January 10, 2018

KD and JD, Parents, Natural Guardians and Next Friends of LD, Plaintiffs,
v.
DOUGLAS COUNTY PUBLIC SCHOOL DISTRICT NO. 001, a/k/a OMAHA PUBLIC SCHOOLS, DANIEL BARTELS, BRIAN ROBESON, JOE DOE and JANE DOE, Real Names Unknown Defendants.

          Jill Robb Ackerman, Leigh Campbell Joyce, BAIRD HOLM LLP, Attorneys for Douglas County School District No. 001, Joe Doe and Jane Doe.

          David A. Domina, Brian E. Jorde, S. Ryan Greenwood, DOMINA LAW GROUP PC LLO, Kathleen Palleson SPETHMAN, PALLESON LAW OFFICES L.L.C., Attorneys for Plaintiffs.

          Clarence E. Mock, JOHNSON & MOCK Attorney for Daniel Bartels.

          STIPULATED PROTECTIVE ORDER

          Cheryl R. Zwart United States Magistrate Judge.

         The Parties expect the disclosure of documents in this case may involve the exchange of sensitive information, including, inter alia, educational information, medical and counseling information, financial and tax information, other personal or business financial information, personally identifying information with respect to Parties, or employees, and/or other information that would be subject to protection from public disclosure. Accordingly, the parties stipulate and agree to, and the Court finds good cause for, entry of the foregoing Protective Order pursuant to Fed.R.Civ.P. 26(c).

         It is hereby ordered that:

         I. Treatment of Confidential Information

         1. All documents containing information that is to be considered confidential information pursuant to this Order shall be marked "CONFIDENTIAL" in large letters on the first page and on each page of the document on which confidential information is contained, if a multi-page document is deemed to be confidential in its entirety, a party may so indicate by marking "CONFIDENTIAL - ENTIRE DOCUMENT" in large letters of the first page of the document. Any party involved in this case, or counsel for such party, may designate as confidential any document, testimony, or information disclosed, or to be disclosed, or portion thereof, if the materia! includes sensitive information. Such designation shall, without more, subject the information produced or provided under said designation to the provisions of this Confidentiality Agreement.

         2. Any party in this case, or counsel for such party, may designate as confidential its responses to interrogatories by labeling each response "CONFIDENTIAL" However, the parties or counsel may not designate as "CONFIDENTIAL" any materials related to a) communications that include or name any Plaintiff or Defendant Robeson, unless it contains the names of students or their parents b) any document required to be disclosed in response to a request made under the Nebraska Public Records Act, Neb Rev Stat § 84-712 et seq., or under the Federal Freedom of Information Act, 5 USC § 552, or any other law permitting discovery of documents or information upon request by a member of the public, c) any document disclosed previously by the School District to law enforcement except those that contain names of students or their parents, or d) any communication about any Plaintiff between or among any personnel of the defendant School District or any other parties.

         3. Subject to the limitations in ¶2, Counsel for any party in this case may designate deposition testimony or any portion of deposition testimony as confidential by advising the court reporter and counsel of such designation during the course of the deposition.

         4. Whenever any material designated as confidential is identified as an exhibit in the above-captioned case, it shall be marked "CONFIDENTIAL" and it shall be subject to all of the requirements of this Confidentiality Agreement.

         5. Inadvertent failure to designate a document as "CONFIDENTIAL" may be corrected by supplemental written notice given as soon as practicable.

         6. The parties must have a good-faith basis in fact and law to designate the material as confidential.

         7. The parties shall act in good faith when determining whether any documents they intend to disclose may contain confidential information and shall make a good-faith effort to designate any such material as being "Confidential, " including but not limited to ...


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