United States District Court, D. Nebraska
LISA J. JERABEK, Plaintiff,
SONNY PERDUE, as Secretary of Department of Agriculture, and HOWARD-GREELEY FARM SERVICE AGENCY, a Nebraska Branch Office of the USDA Farm Service Agency, Defendants.
STIPULATED PROTECTIVE ORDER
Michael D. Nelson United States Magistrate Judge
matter is before the Court on the Parties’ Joint Motion
for Entry of Stipulated Protective Order (Filing 18). 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:
Parties’ Joint Motion for Entry of Stipulated
Protective Order (Filing 18) is granted.
IS FURTHER ORDERED:
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’s employment, medical and healthcare
• Plaintiff’s tax records;
• Confidential or proprietary business information; and
• Employment-related records of the United States
Department of Agriculture and employees or former employees
other than Plaintiff.
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,
Lisa J. Jerabek v. Perdue, et al., 4:19CV03049, and
will not be used in any other litigation.
Defendant is allowed to redact Social Security numbers,
employee identification numbers, home addresses and dates of
birth of employees other than Plaintiff.
Confidential Information shall not, without the consent of
the party producing it or further Order of the Court, be