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Norton v. Lutheran Family Services of Nebraska, Inc.

United States District Court, D. Nebraska

June 11, 2018

BRENDA L. NORTON, an individual, Plaintiff,
v.
LUTHERAN FAMILY SERVICES OF NEBRASKA, INC., a Nebraska nonprofit Corporation Defendant

          STIPULATED PROTECTIVE ORDER

          Honorable Michael D. Nelson United States Magistrate Judge.

         THIS MATTER is before the Court on the Parties' Joint Motion for Protective Order.

         IT IS ORDERED that the Parties' Joint Motion and Protective Order (Filing No. 23) should be granted as follows:

         1. Nondisclosure of Confidential Documents

         (a) Except with prior written consent of the party designating a document to be protected from disclosure, no document designated as CONFIDENTIAL may be disclosed to any person or entity. A party who produces material may designate it as CONFIDENTIAL only when the party in good faith believes it contains proprietary information, trade secrets, privileged information, or nonpublic technical, financial, personal, employment, medical or business information. A document designated as CONFIDENTIAL means any document which bears the legend "CONFIDENTIAL."

         (b) A party receiving from another party any document that has been designated as CONFIDENTIAL may object in writing to the designation and must state the reasons for such objection with respect to each item. The parties shall then meet and confer in good faith regarding the designation. If the parties are unable to come to an agreement regarding the designation, the party challenging the designation shall be obligated to file a motion with the Court challenging such designation.

         (c) This Protective Order shall be without prejudice to the right of any party to: bring before the Court at any time the question of whether any information or documents are confidential; object to the production of any information or documents it reasonably considers not subject to discovery or object to their use at trial; and/or apply to or move the Court for an order compelling production of information or documents or modifying this Protective Order.

         2. Permissible Disclosures of Stamped Confidential Documents

         Notwithstanding paragraph 1, documents designated as CONFIDENTIAL may be disclosed to:

(a) the parties and their legal counsel in these proceedings;
(b) partners, associates, secretaries, paralegal assistants, and employees of such counsel to the extent reasonably necessary to render professional services in the litigation;
(c) persons with prior knowledge of the documents designated as CONFIDENTIAL and confidential information contained therein;
(d) experts who will be providing professional opinions based upon a review of the ...

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