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Streeter v. Saeilo, Inc.

United States District Court, D. Nebraska

October 24, 2018

MICHAEL STREETER, Plaintiff,
v.
SAEILO, INC., Defendant.

          Joseph C. Dowding, Esq. DOWDING, DOWDING, DOWDING & URBOM Attorneys for Michael Streeter

          Jerald C. Rauterkus, Esq. Nicholas Sullivan, Esq. ERICKSON SEDERSTOM, P.C. and Christopher Renzulli, Esq. (pro hac vice) RENZULLI LAW FIRM, LLP Attorneys for Saeilo, Inc., d/b/a Kahr Arms

          ORDER

          CHERYL R. ZWART UNITED STATES MAGISTRATE JUDGE

         STIPULATED PROTECTIVE ORDER

         THE PARTIES TO THIS LAWSUIT: Plaintiff MICHAEL STREETER, by and through his attorneys of record, DOWDING, DOWDING, DOWDING & URBOM, and Defendant SAEILO INC. d/b/a KAHR ARMS, by and through their attorneys of record, RENZULLI LAW FIRM, LLP, and ERICKSON SEDERSTROM, P.C., shall be bound by and adhere to the terms and conditions of the following Protective Order.

         1. Definitions:

(a) “Document” means all written, recorded or graphic matter however produced or reproduced, and all objects and tangible things including, but not limited to, pleadings, records, graphs, charts, audiotapes, videotapes, notes, invoices, electronically-stored data, exhibits, answers to Interrogatories, responses to Requests for the Production of Documents, responses to Requests for Admissions, and deposition transcripts.
(b) “Protected Document” means any document (including, but not limited to, any and all excerpts, digests, summaries or indices thereof) produced during discovery or at the trial of this action which is of a proprietary, confidential, trade secret, or of a commercially and/or competitively sensitive nature and is designated in good faith at the time of production by the producing party to be a “Protected Document.” A “Protected Document” shall continue to be a “Protected Document” until such time as the producing party expressly agrees in writing that the document is no longer considered to be a “Protected Document” or there is a finding by this Court that the document is not the proper subject of protection under Nebraska law.
(c) “Protected Testimony” means any testimony given by way of deposition, Interrogatory or at trial of this action (including, but not limited to, any and all excerpts, digests, summaries or indices thereof) which is of a proprietary, confidential, trade secret or of a commercially and/or competitively sensitive nature and is designated in good faith at the time the testimony is given by the testifying party to be “Protected Testimony.” “Protected Testimony” shall continue to be “Protected Testimony” until such time as the producing party expressly agrees in writing that the testimony is no longer considered to be “Protected Testimony” or there is a finding by this Court that the testimony is not the proper subject of protection under Nebraska law.
(d) “Party” means any party to this action, its parent, subsidiary, or affiliated entities, if any, and its shareholders, directors, officers, employees, and agents or representatives.
(e) “This case” or “this action” or “this litigation” means the above captioned matter currently pending in the United States District Court for the District of Nebraska styled Michael Streeter v. Saeilo, Inc., d/b/a Kahr Arms, No. 4:18-cv-03077-CRZ.

         2. IT IS HEREBY ORDERED AND AGREED that any and all documents produced or to be produced by any party to this action pursuant to any Disclosure, Subpoena, Interrogatory, Request for Production of Documents and/or Request for Admission served by any other party, or testimony given by way of deposition, Interrogatory or at trial for which the producing or testifying party asserts a claim of proprietary, confidential, trade secret or otherwise sensitive commercial information as defined in paragraphs 1 (b) and (c) above and properly designated as “Protected Documents” or “Protected Testimony” shall be subject to this Protective Order. These documents, information, and testimony are to be maintained in a confidential manner under the procedures as hereinafter set forth below.

         3. Without further order of this Court, requesting or receiving parties may show “Protected Documents” and/or “Protected Testimony, ” and may disclose the contents thereof, only to the following persons (hereinafter referred to as “Qualified Persons”):

(a) Counsel of record in this action for requesting or receiving party; counsel of record shall be limited to attorneys who have filed an official appearance with the Court in this action or specifically appeared on pleadings or discovery by listing their name, ...

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