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Central Valley AG Cooperative v. Leonard

United States District Court, D. Nebraska

August 22, 2018

Central Valley Ag Cooperative, Plaintiff,
v.
Daniel K. Leonard et al., Defendants.

         Pursuant to the parties' joint motion, (Filing No. 94), which is hereby granted:

          STIPULATED PROTECTIVE ORDER

          Cheryl Zwart United States Magistrate Judge

         1. Nondisclosure of Certain Confidential Documents.

         (a) “Document” means, without limiting its generality, any physical thing containing information or any written, recorded, graphic or other matter, whether produced, printed, reproduced, or stored on paper, cards, tapes, disks, belts, charges, film, computer storage devices or any other medium, including but not limited to all documents necessary to the comprehension or understanding of any designated document, and includes but is not limited to originals, drafts, redrafts and each separate copy of each document.

         (b) Except as outlined in Paragraph 2 or with prior written consent of the party designating a document to be protected from disclosure, no document produced in discovery in this litigation, including the content thereof, 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, or business information. A document designated as CONFIDENTIAL means (i) any document which bears the legend “CONFIDENTIAL”; and (ii) any electronically stored information produced on a CD, disk, USB drive, or any other medium for producing electronically stored information which bears the label “CONFIDENTIAL.”

         (c) A party receiving from another party any document designated as CONFIDENTIAL may object in writing to the designation within 30 days of receipt of the document 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 document or documents at issue shall remain so designated unless the party challenging the designation files a motion with the Court challenging such designation and the Court grants the motion. The document or documents at issue shall be treated as CONFIDENTIAL and entitled to all protections set forth in this Stipulated Protective Order while any such motion is pending.

         (d) If a document is produced by more than one party and is designated CONFIDENTIAL by only one party, that document will be considered CONFIDENTIAL unless challenged under the provisions of this Stipulated Protective Order.

         (e) This Stipulated Protective Order shall be without prejudice to the right of any party to: 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 to apply to or move the Court for an order compelling production of information or documents.

         2. Permissible Disclosures of Documents Designated CONFIDENTIAL.

         Notwithstanding Paragraph 1, disclosure of documents designated as CONFIDENTIAL, and the information contained therein, shall be limited to:

(a) legal counsel to the parties in these proceedings and partners, associates, secretaries, paralegals, and other employees or vendors of such counsel to the extent reasonably necessary to render professional services in the litigation;
(b) any current or former employee of a party whom legal counsel reasonably believes needs to review or learn of the content of documents designated as CONFIDENTIAL for purposes of providing assistance with this litigation including evaluating settlement of this litigation;
(c) persons with prior knowledge of the documents designated as CONFIDENTIAL and confidential information contained therein;
(d) an expert who will be providing professional opinions based upon a review of the CONFIDENTIAL documents and who has signed a Non-Disclosure Agreement ...

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