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Martin v. Nebraska Methodist Health System

United States District Court, D. Nebraska

April 9, 2018

KIMBERLY L. MARTIN, Plaintiff,
v.
NEBRASKA METHODIST HEALTH SYSTEM, Defendant.

          STIPULATED 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. 24). Good cause having been shown, this motion is granted as follows:

         1. DEFINITIONS.

         Limitations under this Protective Order on the use or disclosure of documents, deposition testimony or other discovery designated as “Confidential” shall apply to (a) all information, copies, extracts and complete or partial summaries prepared or derived from such documents or testimony; (b) portions of deposition transcripts, answers to interrogatories, responses to requests for admissions, responses to requests for production, initial disclosures and exhibits thereto which directly refer or directly relate to any such information, documents, copies, extracts or summaries; and (c) portions of briefs, memoranda or any other writing filed with the Court and exhibits thereto which directly relate to any such information, documents, copies, extracts or summaries.

a. “Confidential Material” or “Confidential Documents” shall mean all documents, material, and information entitled to protection under Fed.R.Civ.P. 26(c) and designated pursuant to paragraph 2 hereof, including, but not limited to, interrogatory answers, documents produced during discovery by any party in this action, whether produced voluntarily, in response to an informal request, pursuant to Fed.R.Civ.P. 26(c) or in response to a formal discovery request, or pursuant to the order of a court of competent jurisdiction, deposition testimony and/or transcripts, and any portions of any pleadings or other court papers that quote from or summarize any of the foregoing.
b. "Requesting Party" shall mean any party requesting documents or information pursuant to Fed.R.Civ.P. 26(c), conducting a deposition pursuant to Fed.R.Civ.P. 30 and 31, propounding interrogatories pursuant to Fed.R.Civ.P. 33, requesting the production of documents pursuant to Fed.R.Civ.P. 34 or pursuant to a subpoena duces tecum served upon any person or entity in this proceeding, and/or otherwise seeking discovery herein.
c. "Producing Party" shall mean any person or entity on whom a discovery request, in whatever form, has been propounded in this action.

         2. CONFIDENTIAL DOCUMENTS.

         Before produced documents are copied or inspected, the producing party may stamp as “Confidential” any document or deposition testimony it believes contains confidential or proprietary business information, information concerning non-parties or subject to privacy rights, including without limitation, HIPAA protected or medical information, and/or trade secrets in order to limit disclosure as set forth in this Paragraph 2. Documents may also be designated as “Confidential” by written notice to opposing counsel which identifies the documents so designated by Bates number. The parties may further restrict such designations for proprietary/trade secret information as "Confidential for Attorney Eyes Only" in which case only attorney may have copies of the documents and may not provide copies to any third party or their client except upon order of the Court or written permission of the producing party. The attorney may, however, review the documents marked "Confidential for Attorney Eyes Only" with their client, in their office so long as counsel is present with the party during any such review. Documents designated “Confidential, ” deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any purpose other than this litigation and will not be disclosed except pursuant to court order entered after notice, to anyone except:

a. Counsel who have signed this Order approving it as to form and content, attorneys who are employed or are members of the law firms or counsel who have signed this Order, in house counsel, law clerks, secretaries, or paralegals directly involved in the conduct of this litigation;
b. Experts and consultants (or any employee of such outside expert or consultant) retained, or sought to be retained by counsel by either of the parties for purposes of assisting in the preparation or presentation of claims or defenses. for purposes of consulting, and/or testifying in this Proceeding, and to whom counsel in good faith has deemed disclosure of such "Confidential" material is reasonably necessary in order to assist in the preparation or the conduct of this Proceeding. This paragraph shall not relieve, change or otherwise affect any obligations or limitations imposed on any person by contract or law regarding disclosure or use of trade secrets or other confidential or propriety information.
c. Any deposition or trial witness, during the course of deposition or trial testimony or preparation for a deposition or trial testimony, when necessary to the testimony of such witness;
d. Outside photocopying, data processing, graphical production services, or any other third-party litigation support vendor employed by the parties or their counsel to assist in this Proceeding.
e. Any person who was involved in the preparation of the document;
f. The Court, Court personnel, court reporters, jurors and similar personnel;
g. The named parties to this case, excluding their agents and/or representatives except those identified at Paragraph 2(a) above.
h. Individuals selected by a party to this Action for the purposes of conducting focus ...

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