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Olsen v. Nelnet, Inc.

United States District Court, D. Nebraska

November 13, 2019

JESSICA OLSEN, and TERI R. SMITH, on behalf of themselves and the Class Members described herein; Plaintiffs,
v.
NELNET, INC., a Nebraska Corporation; NELNET DIVERSIFIED SOLUTIONS, LLC, a Nebraska limited liability company; and NELNET SERVICING, LLC, a Nebraska limited liability company; Defendants.

          STIPULATED PROTECTIVE ORDER

          Michael D. Nelson, United States Magistrate Judge.

         Upon review of the Unopposed Motion for Entry of Stipulated Protective Order Concerning Confidential Information (Filing No. 80), IT IS ORDERED that the Unopposed Motion for Entry of Stipulated Protective Order Concerning Confidential Information (Filing No. 80) is granted. Pursuant to Fed.R.Civ.P. 26(c), this Stipulated Protective Order (the “Order”) shall apply to all documents, materials and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure and designated as “CONFIDENTIAL” pursuant to the terms of this Order. The following terms and conditions shall govern, and are hereby incorporated into, the Order:

         1. DEFINITIONS.

         1.1 Party: Any named party to the Matter, including its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).

         1.2 Discovery Material: All documents, items, or other information, regardless of the medium or manner generated, stored, or maintained (including, without limitation, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery requests in this Matter.

         1.3 “Confidential” Discovery Material: Discovery Material that the Disclosing Party reasonably and in good faith believes contains or would disclose confidential, personal, proprietary, financial, customer, client or commercially sensitive information, that requires the protections provided in this Stipulation and Order, including any information that constitutes confidential information under Fed.R.Civ.P. 26(c) or applicable laws or regulations. Confidential Discovery Material includes information (such as Private Data, as defined in Section 1.7, below) which applicable law requires the equivalent of “Confidential” treatment as set forth in this Order. Confidential Discovery Material shall not include information that is public or that after disclosure becomes public other than by an act or omission of the Receiving Party.

         1.4 Disclosing Party: A Party or non-party which produces Discovery Material in the Matter.

         1.5 Receiving Party: A Party which receives Discovery Material from a Disclosing Party in the Matter.

         1.6 Designating Party: A Party or non-party which designates Discovery Material as “Confidential” pursuant to this Order.

         1.7 “Private Data”: Information that a Party believes in good faith to be subject to data protection laws or other privacy obligations. Nothing in this paragraph shall be used to imply that any law permits, or does not permit, the production of certain data, regardless of whether such data is designated as “Private Data.” 1.8 Outside Counsel: Attorneys, paralegals, and other law firm personnel, employees, and contractors who are not employees of a Party but who are retained to represent or advise a Party in the Matter.

         1.9 In-House Counsel: Attorneys, paralegals, and other legal and/or compliance department personnel who are employees of a Party, to whom disclosure of Discovery Material is reasonably necessary for this litigation.

         1.10 Expert: A person who is not an owner, director, officer, or employee of a Party, who has specialized knowledge or experience pertinent to this Matter, who has been retained by a Party to serve as an expert consultant or witness in the prosecution or defense of the Matter, including his or her employees and support staff.

         2. DESIGNATING DISCOVERY MATERIAL AS “CONFIDENTIAL.”

         2.1 Pursuant to this Order, a Disclosing Party may designate Discovery Material as “Confidential.” The Disclosing Party may make such a designation if it has a reasonable, good faith basis that the information so designated is “Confidential” as a matter of law. The protections conferred by this Order cover not only the Discovery Material itself, but also any information copied or extracted therefrom, as well as copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by Parties or their Outside Counsel to or in Court or in other settings where “Confidential” Discovery Material might be disclosed to persons not authorized to receive it.

         2.2 A Party may designate any Discovery Material as “Confidential” by placing or affixing on them, in a manner that will not interfere with their legibility, the following or other appropriate notice: “CONFIDENTIAL.” Where the designation of Discovery Material as “Confidential” is based in part or in whole on the presence of Private Data, the Disclosing Party may choose to place or affix the following notice: “CONFIDENTIAL - PRIVATE DATA.” Except as otherwise provided in this Order or as otherwise stipulated or ordered, “Confidential” Discovery Material must be designated for protection under this Order before it is disclosed or produced. For depositions, a Party may designate Discovery Material as “Confidential” by indicating in the record at the deposition which portions of the transcript and/or responses shall be treated as “Confidential.” Alternatively, within thirty (30) days after receipt of the transcript or recording of such deposition, the Disclosing Party (or the Designating Party, if different from the Disclosing Party) may designate such transcript or recording or any portion thereof as “Confidential” by notifying all Parties in writing of the specific pages and lines of the transcript or recording that should be treated as “Confidential.” All transcripts or recordings of depositions shall be treated as “Confidential” for thirty (30) days after receipt of the transcript or recording or until written notice of a designation is received, whichever occurs first.

         2.3 In the event that a non-party or another Party discloses Discovery Material that a Party wishes in good faith to designate as “Confidential, ” the Party wishing to make the designation must do so within fifteen (15) days of receipt, and identify the “Confidential” Discovery Material by bates label or, as applicable, by document title and ...


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