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Walz v. Union Pacific Railroad Co.

United States District Court, D. Nebraska

July 23, 2018

TAMRA WALZ, Plaintiff,
v.
UNION PACIFIC RAILROAD CO., Defendant.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge

         This matter is before the Court on the Motion for Protective Order. (Filing No. 38.) The motion will be granted. Accordingly, a Protective Order is entered as follows:

         1. Applicability: This Order shall be applicable to and govern all information and documents designated by the parties as “Confidential Information” which may include, but shall not be limited to deposition transcripts and/or videotapes, and documents produced in response to requests for production of documents, answers to interrogatories, responses to requests for admissions, affidavits, declarations and all other information or material produced, made available for inspection, or otherwise submitted by any of the parties in this litigation pursuant to the Federal Rules, as well as testimony adduced at trial or during any hearing (collectively "Confidential Information").

         2. Scope of Disclosure of Confidential Material. Except as provided elsewhere in this Protective Order, Confidential Information shall be disclosed only to Recipients who fall into the following categories:

a. parties to this litigation and their representatives, including Attorneys for parties to this action;
b. experts (as defined by Federal Rule of Civil Procedure 26(b)(4)), consultants, or persons or firms employed to provide litigation support services, who are not parties to, employees of any party to, or affiliates of any party to, this litigation, provided that such experts, consultants, persons, or firms have first read this Protective Order and agreed in writing to abide by the terms of this Protective Order;
c. any deposition witness, at the witness' deposition, provided that such witness has first read this Protective Order and agreed in writing to abide by the terms of this Protective Order. In this regard, it is understood that Defendant's managerial witnesses who may be deposed will read this Protective Order and sign Exhibit A hereto;
d. any witness to the extent reasonably necessary to prepare that witness to testify at trial or otherwise, provided that such witness has first read this Protective Order and agreed in writing to abide by the terms of this Protective Order;
e. any potential witness to the extent reasonably necessary to determine (i) the extent of what witness' knowledge relevant to this litigation, or (ii) whether that potential witness will in fact be called to testify at trial, provided in either case that such potential witness has first read this Protective Order and agreed in writing to abide by the terms of this Protective Order.

         Any written agreement described in paragraph b, c, d or e shall take the form substantially similar to Exhibit A hereto, and shall be delivered to counsel for Defendant prior to the disclosure of such confidential material to such recipient.

         Notwithstanding the above, disclosures of confidential material may be made, without a pre-signed agreement as described above, to:

(i) the Court, special master, other court personnel, and stenographic and other deposition reporters, provided that such material, if filed before the Court, redact identifying information;
(ii) commercial copying services employed by the parties for the purpose of making copies of document testimony for use in ...

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