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Schmunk v. United States

United States District Court, D. Nebraska

December 23, 2019

CANDACE SCHMUNK, Plaintiff,
v.
UNITED STATES OF AMERICA, Defendant.

          STIPULATED PROTECTIVE ORDER

          SUSAN M. BAZIS UNITED STATES MAGISTRATE JUDGE

         This matter is before the Court on the parties' Joint Motion for Protective Order. (Filing No. 15.) The motion is granted. Accordingly, IT IS ORDERED:

         1. 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.

         2. 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.

         3. 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.

         4. 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 materials;
c. persons regularly employed or associated with the attorneys actively working on the case;
d. Plaintiff, Candace Schmunk;
e. Defendant and Representatives of ...

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