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Creighton University v. Zurich American Insurance Co.

United States District Court, D. Nebraska

June 11, 2018

Creighton University, Plaintiff,
v.
Zurich American Insurance Company and Hartford Steam Boiler Inspection and Insurance Company, Defendants.

         STIPULATED PROTECTIVE ORDER

          Michael D. Nelson United States Magistrate Judge

         Upon the Court's Review of the parties' Joint Stipulation for Protective Order, IT IS ORDERED that the Joint Stipulation for Protective Order (Filing No. 12) is approved, and the parties' stipulation is entered as set forth below:

         In order to expedite the flow of discovery material and resolution of this matter, facilitate the prompt resolution of disputes over confidentiality, adequately protect confidential material, and ensure that protection is afforded only to material so entitled, Plaintiff Creighton University and Defendants Zurich American Insurance Company and The Hartford Steam Boiler Inspection and Insurance Company jointly stipulate to the entry of the following Protective Order.

         1. As used in the Protective Order, these terms have the following meanings:

(a) “Attorneys” means counsel of record;
(b) “Confidential” documents or information are documents or information designated pursuant to paragraph 2;
(c) “Highly Confidential” documents or information are documents or information designated pursuant to paragraph 5;
(d) “Written Assurance” means an executed document in the form attached as Exhibit A.

         2. A party may designate as Confidential any document or portion of any document, discovery response, or transcript that it in good faith believes constitutes or contains non-public business or financial information that the producing party could reasonably expect to harm its business or put it at a competitive disadvantage if disclosed to the public.

         3. All Confidential documents, along with the information contained in the documents, shall be used solely for the purpose of this lawsuit, and no person receiving such documents shall, directly or indirectly, transfer, disclose, or communicate in any way the contents of the documents to any person other than those specified in paragraph 4.

         4. Access to any Confidential document shall be limited to:

(a) The Court, its officials (including court reporters, persons operating video equipment at depositions, and any special master or mediator appointed by the Court), court personnel, and the jury;
(b) Attorneys and their office associates, legal assistants, and stenographic and ...

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