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Senior Housing Managers, LLC v. Highway 2 Development, LLC

United States District Court, D. Nebraska

February 20, 2019

SENIOR HOUSING MANAGERS, LLC, an Oregon limited liability Company, Plaintiff/Counterclaim Defendant,
v.
HIGHWAY 2 DEVELOPMENT, LLC d/b/a Pemberly Place, A Nebraska limited liability company, Defendant/Counterclaim Plaintiff.

          STIPULATED PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge

         This matter is before the Court on the parties' request for protective order. Plaintiff, Senior Housing Managers, LLC and Defendants Highway 2 Development, LLC, hereby stipulate and agree to and request the entry of this Protective Order (“Protective Order”) concerning disclosure, use, and protection of confidential or proprietary documents and information, including, but not limited to, commercial and/or financial information that is not available in the public domain.

         The parties hereby stipulate and IT IS ORDERED as follows:

         1. DEFINITIONS. Limitations under this Protective Order on the use or disclosure of documents, deposition testimony or other discovery designated as "Confidential" shall apply to (a) all information, copies, extracts and complete or partial summaries prepared or derived from such documents or testimony; (b) portions of deposition transcripts, answers to interrogatories, responses to requests for admissions, responses to requests for production, initial disclosures and exhibits thereto which directly refer or directly relate to any such information, documents, copies, extracts or summaries; and (c) portions of briefs, memoranda or any other writing filed with the Court and exhibits thereto which directly relate to any such information, documents, copies, extracts or summaries.

         2. CONFIDENTIAL DOCUMENTS/INFORMATION. The parties seek to protect from disclosure certain confidential, proprietary, personal, and sensitive information relating to this lawsuit. Before produced documents are copied or inspected, the producing party may stamp as "Confidential" on any document or deposition testimony containing such sensitive information. Documents may also be designated as "Confidential" by written notice to opposing counsel which identifies the documents so designated by Bates number. Documents designated "Confidential," deposition testimony so designated, and information derived therefrom will be retained by counsel and will not be used for any purpose other than this litigation and will not be disclosed except pursuant to court order entered after notice, to anyone except:

a. All counsel of record, retained outside counsel, in-house counsel, law clerks, secretaries or paralegals directly involved in the conduct of this litigation, and officers of the Parties;
b. Experts and consultants retained by a party to this action for purposes of assisting in the preparation or presentation of claims or defenses; c. Any deposition or trial witness, during the course of deposition or trial testimony, when necessary to the testimony of such witness;
d. Any person who was involved in the preparation of the document;
e. The Court, Court personnel, court reporters and similar personnel;
f. The named parties to this case, excluding their agents and/or representatives except those identified at Paragraph 2(a) above.
g. Any other person with the prior written consent of the party producing the document, pleading or deposition testimony.

         Prior to receiving or being shown such documents or deposition testimony, the persons falling in the categories listed above in subparagraphs (b), (c), (d), (f) and (g) shall be shown a copy of this Protective Order, and shall execute the attached Acknowledgement and Agreement to be Bound, or on the record during trial or deposition, shall agree to be bound by the terms of this Protective Order. During a deposition, any party asserting confidentiality of any of its documents shall ask the deponent on the record to accept the terms of this Protective Order, If the deponent refuses to assent, disclosure of the documents during deposition shall not constitute a waiver of confidentiality. Under such circumstances, the witness shall sign the original deposition transcript in the presence of the court reporter and no copy of the transcript or exhibits shall be given to the deponent.

         3. DEPOSITIONS. A party that wishes to designate as confidential material any information or testimony that is contained in a deposition transcript, shall indicate orally at the time of the deposition that it intends to designate all or part of the information or testimony as confidential. Within thirty (30) days after receipt of the deposition transcript, the designating party shall advise the other parties of the specific portions of the information or testimony it contends are confidential, unless the parties agree to an extension of that period of time. Until the period of time for designation has passed, or until the Court has ruled on any disputed designations of confidentiality, the parties shall treat the designated portions of any deposition transcripts as confidential.

         4. DOCUMENTS ALREADY PRODUCED. Within thirty (30) days of the entry of this Order, parties may inform the party to whom documents have been produced that it considers certain documents already produced as being subject to this Order as "Confidential." 5. THIRD PARTY WITNESSES. Either party may designate documents produced by a third party as being "Confidential" pursuant to the terms of this Protective Order within thirty (30) days of being made aware of the content of such documents. Any document produced by a third party shall be treated as "Confidential" pursuant to the terms of this Protective Order for such thirty (30) day period and thereafter if designated as "Confidential" by either party to this litigation. The "Confidential" restrictions of this Protective Order shall no longer ...


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