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Kime v. Titeflex Corp.

United States District Court, D. Nebraska

October 16, 2019

DALLAS and CARMEN KIME, Plaintiffs,
v.
TITEFLEX CORPORATION, Defendant.

          PROTECTIVE ORDER

          Susan M. Bazis United States Magistrate Judge.

         A protective order is hereby entered as follows:

         1. As set forth in this paragraph, documents, information or testimony containing or relating to confidential, proprietary, research, development, financial, business information and/or trade secrets may be designated by a Party disclosing (the “Disclosing Party”) or who has produced the document, information, or testimony as “Confidential Information” or “Highly Confidential Information” (Referred to in Exhibit A as “Protected Documents”). Such designation may be made, for example, by marking or labeling documents produced in this litigation with the terms “Confidential” or “Highly Confidential” or by any other reasonable means of providing notice. As used herein, the terms or designations of “Confidential” or “Highly Confidential” shall be synonymous. The Disclosing Party must take care to limit any designation to specific material that qualifies under the appropriate standards of confidentiality and, in any case, such designations must be made with a good-faith understanding of the claim of confidentiality.

         2. At any time after the disclosure, production, or delivery of materials designated “Confidential” or “Highly Confidential, ” the Party receiving the designated material (“Receiving Party”) may challenge the designation of all or any portion thereof by providing written notice thereof to the Disclosing Party, identifying with particularity the specific materials that the Receiving Party wishes to challenge. If the Parties are unable to agree as to whether the “Confidential” or “Highly Confidential” designation is appropriate, the Receiving Party shall within a reasonable time file a motion to compel the production of the materials at issue with a different designation. Once this issue is raised with the Court by way of motion to compel, the Disclosing Party shall have the burden of establishing that the materials at issue are entitled to confidential treatment under this Order. All documents or materials that have at any time been labeled, marked or otherwise designated as “Confidential” or “Highly Confidential” shall at all times be treated confidentially under this Order unless and until the Parties formally agree in writing to the contrary, or the Court rules that the materials are not entitled to the designation given by the Producing Party.

         3. Materials designated as “Confidential” or “Highly Confidential” and any information contained therein, including translations, summaries and distillations thereof, shall not be used or shown, disseminated, copied, or in any way communicated to anyone for any purpose whatsoever, except that such materials designated as “Confidential” or “Highly Confidential” may be disclosed to the following persons:

a. Counsel of record in this action;
b. Employees of counsel of record in this action (excluding experts and investigators) who are assigned to and necessary to assist such counsel in the preparation and trial of this action;
c. The Parties, their officers and employees assigned and necessary to assist such counsel in the preparation and trial of this matter, and claim representatives/adjusters of the Parties' insurance carriers who are assigned to supervise the claim in this action;
d. Subject to Paragraph 19 below, non-party witnesses or deponents and their counsel solely for purposes of their role as a witness or deponent in this litigation;
e. The Court, court personnel, and court reporters;
f. Subject to Paragraph 19 below, to consultants and experts retained by the Parties and their attorneys for purposes of this litigation;
g. The jury; and
h. Third-party copy services for the sole purpose of creating a copy as defined in Paragraph 7 below.

         4. Any documents or information produced during the course of discovery shall be used solely for the prosecution and defense of claims in the above-captioned lawsuit, and shall ...


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