Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

King v. Catholic Health Initiatives

United States District Court, D. Nebraska

October 10, 2018

JENNIFER M. KING, Plaintiff,
v.
CATHOLIC HEALTH INITIATIVES, a nonprofit foreign corporation operating in Nebraska, Defendant.

          STIPULATED PROTECTIVE ORDER

          MICHAEL D. NELSON, UNITED STATES MAGISTRATE JUDGE

         THIS MATTER comes before the Court upon the parties' stipulated motion for Protective Order (Filing No. 25). The proposed stipulated order was emailed to the undersigned magistrate judge and signed by counsel for both parties. The Court, being duly advised of the premises herein, finds that in order to expedite the flow of discovery material, facilitate the prompt resolution of disputes over confidentiality, and adequately protect material to be kept confidential, IT IS HEREBY ORDERED as follows:

         1. Documents or information have been and may be requested, produced, or used as an exhibit in this matter, which contain valuable trade secrets, confidential materials, and other proprietary information (hereafter, "Confidential Information").

         2. To protect such Confidential Information, the parties may designate as "Confidential" any document(s) produced, or information provided, in response to a discovery request. The designation shall be completed in one of the following manners:

a. By imprinting the word "Confidential" on the front of the document or on the label or cover for any compact disc or flash drive containing Confidential Information;
b. By imprinting the word "Confidential" next to or above any answer to any written discovery response; or
c. With respect to deposition transcripts and videos, by making arrangements with the attending court reporter to label such transcripts and videos as "Confidential."

         Designating documents or information as “Confidential” does not mean that the document or information has any status or protection by statute or otherwise, except in accordance with this Protective Order.

         3. All documents and information designated as "Confidential" shall be used only for the purpose of this litigation and not for any other purposes whatsoever. In addition, such documents and information shall be furnished and handled solely in accordance with this Protective Order or subsequent order of the Court.

         4. All documents and information designated as "Confidential" (including, but not limited to, any information or testimony discussing, derived from, or referring to such documents or information), shall not be communicated, disclosed, or produced in any manner, either directly or indirectly, to anyone other than:

a. The attorneys of record in this case and their office employees;
b. The parties in this case, including their officers and employees, who have a need to know for purposes of this litigation;
c. Outside consulting and retained experts who have, prior to the disclosure of any documents or information marked as "Confidential," agreed to be bound by the terms of this Protective Order by executing the Nondisclosure Agreement attached hereto as Exhibit "A";
d. Any fact witness who has, prior to the disclosure of such documents or information marked as "Confidential," agreed to be bound by the terms of this Protective Order by executing the Nondisclosure Agreement ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.