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Gegner v. Admiral Merchants Motor Freight, Inc.

United States District Court, D. Minnesota

March 4, 2019

Patricia Gegner, Plaintiff,
v.
Admiral Merchants Motor Freight, Inc., Defendant.

          PROTECTIVE ORDER

          Tony N. Leung United States Magistrate Judge

         This matter is before the Court on the parties' Stipulation for Protective Order. (ECF No. 13). Based on the stipulation of the parties, and all the files, records, and proceedings herein, IT IS HEREBY ORDERED that pursuant to Fed.R.Civ.P. 26(c), confidential information shall be disclosed in the designated ways:

         1. Definitions. As used in this Protective Order:

(a) “attorney” means an attorney who has appeared in this action;
(b) “confidential material” means information, documents, testimony, and other discovery from any party or third party designated pursuant to paragraph 2 of this Protective Order;
(c) to “destroy” electronically stored information means to delete from all databases, applications, and file systems so that the information is not accessible without the use of specialized tools or techniques typically used by a forensic expert;
(d) “document” means information disclosed or produced in discovery, including at a deposition;
(e) “notice” or “notify” means written notice;
(f) “party” or “parties” means one or more party to this action;
(g) “protected document” means a document protected by a privilege or the work-product doctrine; and
(h) “Written Assurance” means an executed document in the form attached as Exhibit A to this Protective Order.

         2. Designating Confidential Material.

(a) A party or non-party disclosing or producing a document may designate it as confidential if the party or non-party contends that it contains confidential or proprietary information.
(b) A party or non-party may designate a document as confidential by conspicuously marking each page with the word “confidential.”
(c) Deposition testimony may be designated as confidential:
(1) on the record at the deposition; or
(2) after the deposition, by promptly notifying the parties and those who were present at the deposition.
(d) If a witness is expected to testify as to confidential or proprietary information, a party or non-party may request that the witness's deposition be taken in the presence of only those persons entitled to receive confidential material, including those who have signed a Written Assurance.

         3. Who May Receive a Confidential Document.

         (a) All confidential material shall be used solely for the purpose of this action, and no person receiving such documents shall, directly or indirectly, transfer, disclose, or communicate in any way the contents of confidential material to any person ...


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