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Equal Employment Opportunity Commission v. Drivers Management, LLC

United States District Court, D. Nebraska

February 12, 2019

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, et al. Plaintiffs,
v.
DRIVERS MANAGEMENT, LLC et al, Defendants.

          STIPULATED PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge

         This matter is before the Court upon the request of the parties in their Rule 26(f) Report (Filing No. 20) for the entry of a protective order.

         Having considered the matter, this Court enters the following Protective Order governing the confidential and proprietary information obtained in this case.

         1. Definitions

a. “Party” means Plaintiff EEOC and Defendants Werner Enterprises, Inc. and Drivers Management, LLC, and any other person or entity that may become a party to this litigation.

         2. Only the following materials obtained during the course of this case are deemed private and confidential and subject to this Order:

(A) Trade secrets;
(B) Health records, audiological records, or other Protected Health Information (as defined by federal law);
(C) Financial records, such as balance sheets, profit and loss statements, income tax returns, W-2s and/or pay stubs;
(D) Personnel records;
(E) Records and testimony relating to Conciliation of the underlying charges; and
(F) Non-public proprietary business records, including but not limited to leave records, personnel policies, workers' compensation records, and employees' medical information.

         3. Documents designated by a party as confidential pursuant to this Protective Order shall remain confidential, and absent permission by the Court, will be used only for the purpose of preparation and presentation of this case. Any documents produced or information provided by a party pursuant to or in response to any discovery request may be designated as "Confidential" in the following manners:

(A) By imprinting the word "Confidential" on the first page or cover of any document ...

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