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Cronin v. Peterson

United States District Court, D. Nebraska

May 1, 2018

TIMOTHY CRONIN, Plaintiff,
v.
CHRIS PETERSON, in his individual capacity; TONYA PETERS, in her individual capacity; WILLIAM KOEPKE, in his individual capacity; and DAREN REYNOLDS, in his individual capacity, Defendants.

          PROTECTIVE ORDER

          Susan M. Bazis, United States Magistrate Judge

         This matter is before the Court for consideration on parties' Joint Stipulation for Protective Order. (Filing No. 36.) Upon consideration, the Court hereby enters a protective order as follows:

         1. Confidential Information.

         This Protective Order applies to all Confidential Information produced by a party in this case, whether revealed in a document, deposition, an interrogatory answer or otherwise. All documents and every portion thereof produced by the Defendants or that relate to or contain the Defendants' and their employees' employment and personnel files shall constitute CONFIDENTIAL information for the purposes of this Order and shall be used by the receiving party only for the preparation for and conduct of proceedings herein and not for any business or other purpose whatsoever. The CONFIDENTIAL information shall not be used or Disclosed by Plaintiff's Attorney, or anyone else for any purpose unrelated to this litigation or for any business or competitive purpose. Disclosure other than as provided for herein shall first require written consent of the Producing Party, or by order of the Court. Plaintiff's Attorney shall maintain a list of documents disclosed and to whom. Plaintiff's Attorney shall also require anyone receiving confidential documents to agree to the terms of this Agreement. Should Plaintiff and/or his Attorney question whether documents designated as Confidential Documents are truly confidential, they should first contact the Producing Party to resolve the issue. If the issue cannot be resolved, Plaintiff's Attorney may petition the Court for an order declaring that the document is not subject to the conditions of this Protective Order. The Plaintiff's Attorney shall be responsible for instructing witnesses, consultants, and outside counsel assisting in preparation of the case that disclosure of the Confidential Documents is prohibited as set forth herein.

         2. Qualified Recipients. For the purposes of this Order, persons authorized to receive “CONFIDENTIAL” information (hereinafter “qualified recipient”) shall include only:

a. The Parties, including any members, council members, officers, board members, directors, employees, or other legal representatives of the parties;
b. Legal counsel representing the Defendants and legal counsel representing the Plaintiff, and members of the paralegal, secretarial, or clerical staff who are employed by, retained by, or assisting such counsel;
c. Consulting or testifying expert witnesses assisting any legal counsel in the preparation of this case and staff and assistants employed by the consultant or testifying expert;
d. The parties' insurers and their staff and assistants, members, officers, board members, directors or other legal representatives;
e. The Court, and Court staff, and any court reporter or typist recording or transcribing testimony, and jurors;
f. Any mediator retained by the parties in an effort to mediate and/or settle the claims of this action and members of the mediator's staff and assistants.

         3. Maintenance of Confidentiality. CONFIDENTIAL information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, and shall not be disclosed to any person who is not a qualified recipient. Each party, each qualified recipient, and all counsel representing any party, shall use their best efforts to maintain all produced CONFIDENTIAL information in such a manner as to prevent access, even at hearing or trial, by individuals who are not qualified recipients. Nothing herein shall prevent disclosure beyond the terms of this Protective Order if the party claiming confidentiality consents in writing to such disclosure.

         4. Copies. CONFIDENTIAL information shall not be copied or otherwise reproduced by the receiving party, except for transmission to qualified recipients, without the written permission of the producing party, or, in the alternative, by further Order of the Court. However, nothing herein shall restrict a qualified recipient from making working copies, abstracts, digests, and analyses of CONFIDENTIAL information under the terms of this Order.

         5. Filing Under Seal. All documents of any nature (including any of the foregoing documents as well as any other documents, including, but not limited to, briefs, motions, memoranda, transcripts, and the like) that are filed with the Court for any purpose and that contain CONFIDENTIAL information shall be filed in sealed envelopes or other sealed containers marked with the title of the action and ...


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