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Gimenez v. Heartland Dental, LLC

United States District Court, D. Nebraska

February 22, 2018

PETER J. GIMENEZ, D.D.S., P.C. d/b/a HEARTLAND DENTAL, Plaintiff,
v.
HEARTLAND DENTAL, LLC, a Delaware limited liability company, Defendant.

          PROTECTIVE ORDER

          SUSAN M. BAZIS UNITED STATES MAGISTRATE JUDGE.

         This matter is before the Court on the parties' Joint Motion for Protective Order. (Filing No. 29.) The motion is granted.

         Accordingly, IT IS ORDERED as follows:

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 material includes sensitive information. Such designation shall, without more, subject the information produced or provided under said designation to the provisions of this Confidentiality Agreement. Documents produced in this action prior to the effective date of this Confidentiality Agreement that are marked “CONFIDENTIAL” shall be treated as confidential for purposes of this 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.” 3. 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. For example, the parties will not designate any publicly-available 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 social security numbers and medical/healthcare-related information.
8. The parties shall treat as confidential any information related to the medical history and/or treatment of any person identified by Parties as having information relevant to this litigation, regardless of the method by which such information was obtained and regardless of whether such information has been disclosed in any manner prior to the date of this Order. Without limiting the foregoing, any of the parties' discovery requests or responses that reference, contain, or attach information or documents related to such medical history and/or treatment are hereby designated as confidential and subject to the provisions of this Order. The fact that such information is not marked as “Confidential” or that it was received by a third party or disclosed prior to the entry of this Protective Order shall not alter the parties' obligations under this paragraph.
9. The Parties shall file the Notices of any Third-Party Subpoenas and the Subpoenas as Restricted if they contain the names of the Plaintiffs. The Parties acknowledge that the names of the Plaintiffs whose records are being sought will appear in the subpoena that will be served. The medical, school, counseling, and employment records of the Parties or their families shall be treated as Confidential under this Order.
10. If any party objects to the designation of any information as confidential, that party shall meet and confer with opposing counsel within thirty (30) business days of receipt of this objection in an effort to resolve any such dispute. If the parties are unable to resolve such dispute, the party designating the material as confidential may move to have the Court declare the contested information confidential. A party failing to object to a confidentiality objection within the foregoing thirty-day window who later comes into possession of information indicating that the initial designation was improper may seek leave of the Court for a motion to strike the confidentiality designation.
11. Confidential information includes all material designated confidential, pursuant to the terms of this Order, as well as summaries and compilations derived from such confidential materials, including but not limited to charts, tables, graphs, and models.
12. If non-confidential information is contained in or otherwise derived from confidential materials, any portion that consists solely of non-confidential information shall ...

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