United States District Court, D. Nebraska
ELBA ALICIA ORDONEZ VELAZQUEZ, LUIS ALBERTO ARRIAGA GUZMAN, Husband and Wife, Plaintiffs,
THE UNITED STATES OF AMERICA, JOHN or JANE DOE, M.D., Real Names Unknown, Defendants.
STIPULATED PROTECTIVE ORDER
M. Bazis, United States Magistrate Judge
matter is before the Court on the parties' Joint Motion
for Entry of Stipulated Protective Order. (Filing No.
17.) Upon a showing of good cause in support of the
entry of a protective order to control the discovery and
dissemination of confidential or proprietary information in
this case (hereafter collectively referred to as
“Confidential Information”), IT IS ORDERED THAT:
Confidential Information will include confidential or
proprietary business information. For purposes of this Order,
the following categories of documents and information will
generally be considered “Confidential
Information” and subject to this Protective Order:
• Plaintiff, Elba Alicia Ordonez Velazquez's,
medical or healthcare records or tax records;
• Confidential or proprietary business information.
Confidential Information subject to this Protective Order
may, depending on the content, be included in a variety of
documents, including but not limited to: Agency records,
documents produced pursuant to written discovery, answers to
interrogatories, responses to requests for admission,
deposition testimony, including all copies thereof, and other
information disclosed in the context of discovery of this
case by either party or disclosed pursuant to the discovery
procedures created by the Federal Rules of Civil Procedure.
Confidential Information shall not be disclosed or used for
any purpose except the preparation and trial of this case,
Elba Alicia Ordonez Velazquez, Luis Alberto Arriaga
Guzman, Husband and Wife v. The United States of America,
John or Jane Doe, M.D., Real Names Unknown, and will not
be used in any other litigation.
Confidential Information shall not, without the consent of
the party producing it or further Order of the Court, be
disclosed except that such information may be disclosed to:
a. attorneys actively working on this case;
b. any person who previously received or authored the
c. persons regularly employed or associated with the
attorneys actively working on the case;
d. Plaintiffs Elba Alicia Ordonez Velazquez and Luis Alberto
e. treating medical providers, expert witnesses, and
consultants retained in connection with this proceeding;
f. mediators, facilitators, or other persons retained by the
parties to assist in the resolution of this ...