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Lanham v. General Motors, LLC

United States District Court, D. Nebraska

February 7, 2018

GLENN TODD LANHAM, Plaintiff,
v.
GENERAL MOTORS, LLC, Defendant.

          David A. Brose, Mo. Bar #56244 Michael J. Serra, Mo. Bar #63227 Admitted to Practice in the District of Nebraska LANGDON & EMISON Counsel for Plaintiff Glenn Todd Lanham

          Rodney E. Loomer Mo. Bar #24013 Jeffrey D. Upp, Mo. Bar #69471 Admitted to Practice in the District of Nebraska TURNER, REID, DUNCAN, LOOMER & PATTON, P.C. Counsel for Defendant General Motors, LLC

          AGREED PROTECTIVE ORDER

          CHERYL R. ZWART, PRESIDING JUDGE

         On this day, the Court was presented with this Agreed Protective Order, submitted by Plaintiff and Defendant General Motors LLC (“General Motors”), to govern the disclosure of certain documents to be produced by General Motors in the course of discovery and trial of this action.

         WHEREAS, documents or information proprietary to General Motors containing confidential, financial, proprietary, technical and commercial information may be produced or disclosed during the course of discovery in this litigation;

         WHEREAS, disclosure of such confidential information might be severely injurious to General Motors, placing it at a competitive disadvantage within the industry;

         WHEREAS, good cause has been shown for the entry of a protective order; WHEREAS, the parties wish to proceed with discovery in this action without burdening the Court with unnecessary procedural litigation.

         1. Any document, data or other material, including but not limited to photographs, drawings, films, videotapes, electronically stored information or other data (“documents”), which contain commercially sensitive or proprietary information may be designated as confidential by the producing party. All such documents designated as confidential, and copies thereof, shall be marked “Subject to Protective Order” or “Confidential” or with substantially similar language, or as described in Paragraph 14 of this Order and shall contain the name of the producing party and the style of this lawsuit. No such markings shall obscure the material being produced.

         2. Prior to the disclosure of any documents or information covered by this Order, the attorney making such disclosure shall furnish a copy of this Order to the person, firm, or corporation to whom the documents or information contained therein is to be disclosed, and shall advise such persons that, pursuant to this Protective Order, such documents or information contained herein, may not be divulged or disseminated, in any way, to any other person, firm or corporation. No person to whom documents or information subject to restricted access are disclosed pursuant to the provisions of this Order shall disclose the materials to any person not entitled, under the terms of this Order, to receive it.

         3. All such recipients of protected documents or information shall, by receiving documents or information produced subject to this Protective Order, submit to the jurisdiction of United States District Court for the District of Nebraska, for the purposes of any action seeking to enforce the terms and conditions of this Order or any action for contempt for violation of the terms of this Order. All persons to whom the information is disclosed will provide their name, address and telephone number as provided on the attached Exhibit A, evidencing their agreement to the terms of this Order. The names, addresses, and telephone numbers of all experts shall be entered on Exhibit A. Absent a showing of good cause, the expert information contained in Exhibit A need not be disclosed to opposing counsel until after conclusion of the litigation, including appeals.

         4. The Parties shall undertake, in good faith, to designate as confidential only those documents which they believe contain commercially sensitive or proprietary information.

         5. Plaintiff shall not disseminate confidential documents or information produced pursuant to this protective order, except as otherwise provided herein.

         6. Confidential documents and information, and any copies thereof, may be disclosed to deponents during the course of their preparation for, and the taking of, their depositions. Prior to the disclosure of such documentation or information to a deponent, the attorney making the disclosure shall have the deponent sign Exhibit A and advise the deponent to whom the documents or information contained therein are to be disclosed that, pursuant to this Order, such deponent may not divulge any such documents or information contained therein to any other person, firm or corporation.

         7. In the event that any such confidential documents or information is included with, or the contents thereof are in any way disclosed by any pleading, motion, deposition transcript, or other paper filed with the Court, such documents and information shall be kept confidential and automatically kept under restricted access until further Order of the Court. The sealing is necessary because General Motors has a specific, serious, and substantial proprietary interest, and there is no adverse effect that sealing of these documents will have upon the general health and public ...


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