United States District Court, D. Nebraska
STIPULATED PROTECTIVE ORDER
M. BAZIS UNITED STATES MAGISTRATE JUDGE
matter is before the Court on the parties' Joint Motion
for Protective Order. (Filing No. 15.) The motion is granted.
Accordingly, IT IS 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:
• Candace Schmunk's medical or healthcare records;
• Candace Schmunk's tax records;
• Confidential or proprietary business information.
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,
Candace Schmunk v. United States of America, and
will not be used in any other litigation.
Confidential Information shall not, without the consent of
the party producing it or further Order of the Court, be
disclosed except that such information may be disclosed to:
a. attorneys actively working on this case;
b. any person who previously received or authored the
c. persons regularly employed or associated with the
attorneys actively working on the case;
d. Plaintiff, Candace Schmunk;
e. Defendant and Representatives of ...