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Meyer v. Currie Tech Corp.

United States District Court, D. Nebraska

January 31, 2018

MICHAEL MEYER, an Individual, and MARCIE MEYER, an Individual, Plaintiffs,
v.
CURRIE TECH CORP., a Delaware Corporation, and ACCELL NORTH AMERICA, INC., a Delaware Corporation, Defendants.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         This matter is before the Court upon the Joint Motion for Protective Order. (Filing No. 41.) Having considered the matter, the motion is granted.

         Accordingly, IT IS ORDERED that all information, including documents, photographs, and testimony produced and obtained during the course of discovery which the producing party claims constitutes or contains confidential or proprietary information (hereinafter referred to as “Confidential Information”) and has therefore marked or otherwise designated as confidential in the manner set forth below, is subject to the following terms and conditions:

         1. For purposes of this Agreement, “Confidential Information” means: (a) any policies of liability insurance covering Currie Tech Corp. Accell North America, Inc., and Accell Group N.V., and (b) any documents and/or correspondences containing trade secrets and/or proprietary information produced hereinafter that are designated as confidential by Currie Tech Corp. and Accell North America, Inc.

         2. Confidential Information shall be designated as such pursuant to the following conditions:

a. In the case of documents (including electronically stored information) produced in hard copy or electronically, by placing the word “Confidential” on each page designated confidential provided, however, Social Security numbers of non-party employees may be redacted prior to disclosing documents containing such information;
b. In the case of responses to written discovery, by inserting the word “Confidential” prior to each response containing Confidential Information; and
c. In the case of depositions, by either designating testimony as confidential on the record during the deposition or in correspondence sent to all parties within 30 days after receipt of the transcript of the deposition, provided, however, all depositions of the parties or their current or former employees shall be deemed to be Confidential Information until 30 days after receipt of the transcript of the deposition.

         3. The protection granted by this Order shall encompass the documents in their entirety. Upon receiving the Confidential Information, counsel is responsible for abiding by the terms and conditions of this Protective Order.

         4. Inadvertent failure to so designate prior to production as set out in paragraphs 2 “a”-“c” will not prevent a subsequent “Confidential” designation. Any use of such documents prior to actual notice of designation as “Confidential” shall not constitute a violation of this Order.

         5. Counsel may be provided with a single copy of the Confidential Information, except as otherwise agreed between the parties' counsel. No. copies are to be made, other than those necessary for counsel to use in accordance with this Protective Order, in preparation for the case and those incidental to incorporation into a Brief or other document or material to be filed with this Court.

         6. In the event that either party files with the Court any Confidential Information supporting a discovery Motion, dispositive Motion, or pre-trial Motion, counsel shall file such documents under seal pursuant to the Rules of this Court.

         7. Confidential Information shall only be disclosed or disseminated to, and used by, persons identified as “Qualified Persons” defined in paragraph 8 “a”-“e” for purposes of this litigation or any appeals ...


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