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Kinsella v. First Data Resources, LLC

United States District Court, D. Nebraska

November 7, 2018

TERESA KINSELLA, Plaintiff,
v.
FIRST DATA RESOURCES, LLC, and FIRST DATA CORPORATION, Defendants.

          STIPULATED PROTECTIVE ORDER

          Susan M. Bazis, United States Magistrate Judge.

         This matter is before the Court on the parties' Joint Motion for Protective Order. (Filing No. 17.) The motion is granted.

         Accordingly, 1. Information (whether in the form of documents, interrogatory responses, deposition testimony, or other form) produced or exchanged by any of the parties to this action, or any of their attorneys, concerning employment and/or personnel records, medical/health information and/or records, criminal records and/or information, educational records not otherwise public, wage information and non-public, proprietary business records, documents and financial data, and trade secret information shall not be disclosed except as provided in this Order. The above information shall hereafter be referred to as "Confidential Information" in this Order, and shall be designated as such pursuant to paragraph 3, below. Counsel for the party designating any information as confidential may, in writing and without Court approval, agree to release any of the Confidential Information from the requirements of this Order. Defendants shall not designate as “Confidential” any of Plaintiff's own personnel records or medical/health information to restrict Plaintiff's usage of such documents herein, but Defendants shall itself treat such information as “Confidential” under this Order.

         2. All Confidential Information produced or obtained from any other party in the course of this action, through discovery or otherwise, shall be used by the party to whom such information is produced solely for the purpose of this litigation and for no other purpose and the Confidential Information shall not otherwise be disclosed to any other persons than those designated in Paragraph 4, below. Confidential Information may be used in a manner consistent with the terms of this Order and subject only to the limitations stated in this Order, in pretrial discovery and at the trial or preparation for trial and any appeals of this action.

         3. Documents or information produced or provided by the parties during the course of discovery may be designated as “Confidential Information” as long as the party seeking confidentiality has a good faith belief that such document or information is entitled to confidentiality under the terms of this Order. To designate information as “Confidential, ” the producing party shall place a legend or stamp upon the document that places the recipient on reasonable notice that it contains “Confidential” information. Inadvertent failure to designate as “Confidential” shall not be construed as a waiver, in whole or in part, and may be corrected by the producing party by written notification to the recipient promptly upon discovery of the failure to designate. Any use of such documents prior to actual notice of designation as “Confidential” shall not constitute a violation of this Order. The parties will follow the Court's administrative procedures for electronically filing documents subject to this Protective Order.

         4. Neither the Confidential Information nor its contents shall be disclosed to any person, without the agreement of the party designating the information as confidential, PROVIDED that counsel may, without further agreement or Court order, disclose Confidential Information or its contents to the following persons for use solely in connection with this action:

a. The named parties to this action, all of whom have agreed to be bound and are bound by the terms of this Order;
b. Plaintiff's spouse;
c. Attorneys and legal assistants of counsel's firm and to any other employees of counsel's firm who shall handle the Confidential Information under normal office procedure;
d. Experts or consultants retained by the parties in this action, and non-retained experts (i.e., treating medical providers);
e. Any person who is an officer, director or employee of any reproduction or litigation document handling service whom counsel specifically authorizes to work on this case;
f. Any person from whom testimony is being taken, has been taken or is reasonably expected to be taken in this action (whether in deposition or at trial), at a reasonable time before such testimony or during such testimony;
g. The Court and its personnel before which this action is pending and any members of a jury; and
h. Any court reporters and/or videographers present in their official capacity at any hearing, deposition or other ...

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