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Hayhurst v. Union Pacific Railroad Co.

United States District Court, D. Nebraska

July 30, 2019

Mark Hayhurst, Plaintiff,
v.
Union Pacific Railroad Co., Defendant.

          JOINT STIPULATED PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         This matter is before the Court on the parties' Joint Motion for Stipulated Protective Order, (Filing No. 25). This motion is granted.

         Accordingly, a Protective Order is entered 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 nay such information, documents, copies, extracts or summaries.

         2. CONFIDENTIAL DOCUMENTS: Before produced documents are copied or inspected, the producing party may stamp “Confidential” any documents or deposition testimony it believes contains confidential information concerning nonparties, confidential or proprietary business information and/or trade secrets in order to limit disclosure as set forth in Paragraph 2. 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 excerpt pursuant to Court order entered after notice, to anyone except:

a. Counsel who have signed the Order approving it as to form and content, attorneys who are employed or are members of law firms of counsel who have signed this Order, in house counsel, law clerks, secretaries or paralegals directly involved in the conduct of this litigation;
b. Experts and consultants retained by either of the parties for the purposes of assisting in the preparation or presentation of claims or defenses;
c. Any deposition or trial witness, during the course of deposition, pretrial investigation or trial testimony, when necessary to the testimony of such witness;
d. Any person who was involved in 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; and
h. Any witness whom counsel needs to question concerning a document or information for the purpose of the case.
i. Outside independent persons (i.e.. persons not currently or formerly employed by, consulting with, or otherwise associated with any party) who are retained by a party or its attorneys to provide assistance as mock jurors or focus group members or the like, to furnish ...

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