United States District Court, D. Nebraska
DANA L. SIEMERS, Plaintiff,
BNSF RAILWAY COMPANY, a Delaware corporation; Defendant.
M. Bazis United States Magistrate Judge
matter is before the Court on the parties' Stipulated
Motion for Protective Order. (Filing No. 92.) This
motion is granted.
Protective Order shall apply to all Confidential Information
produced or discovered in BNSF's Response to
Plaintiff's Request for Production No. 21 (“RFP No.
Confidential Information produced or discovered in RFP No. 21
shall not, without the written consent of the Parties or
further Court Order, be used or disclosed for any purpose
except in the preparation and trial of this case (including
purposes of this Order, “Confidential
Information” means any document or information
designated as confidential, including without limitation,
non-public commercial or proprietary information about the
finances or business practices of any party to this lawsuit
and trade secrets or other intellectual property information,
data or research of any named party in this action. This
includes, without limitation, all documents or information
produced in response to RFP No. 21. Confidential Information
shall include copies of the Qualified Mechanical Inspectors
exam in effect in 2015 and 2016, and any other information
expressly designated “Confidential” by counsel of
record in this matter.
shall make such designation only after review of the
information and upon a good faith belief that the designation
is appropriate because the subject information is
confidential and implicates common law or statutory privacy
Documents are designated as Confidential Information by
placing or affixing on them (in a manner that will not
interfere with their legibility) a label of
“Confidential” or other appropriate notice.
Confidential Information produced or discovered in response
to RFP No. 21 may only be disclosed to the following:
a. attorneys and attorney staff actively working on this
b. Parties, including the designated representatives of
parties that are legal entities;
c. expert witnesses and consultants retained in connection
with this proceeding;
d. the Court;
e. reporters engaged in this ...