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Bro Dk Orb Protective Order

Bro Dk Orb Protective Order

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Published by Brian Bakst

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Published by: Brian Bakst on Jun 07, 2013
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06/07/2013

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UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTAMICHAEL BRODKORB, Civil No. 12-1958 SRN/AJBPlaintiff,v. ORDER MINNESOTA SENATE,Defendant.IT IS HEREBY ORDERED that the attached Protective Order shall govern the discovery in the abovematter.Dated: June 6, 2013s/ Arthur J. BoylanARTHUR J. BOYLANUnited States Chief Magistrate Judge
CASE 0:12-cv-01958-SRN-AJB Document 58 Filed 06/06/13 Page 1 of 8
 
2.UNITED STATES DISTRICT COURTDISTRICT OF MINNESOTAMichael Brodkorb,Plaintiff,v.Minnesota Senate,Defendant.File No. 12-CV-01958 (SRN/AJB)Case type: Employment
PROTECTIVE ORDER
The parties to the above-entitled matter came forth and requested a Protective Order, both partiessubmitted a separate proposed Protective Order and this Court, having reviewed the proposed Protective Ordersenters the following PROTECTIVE ORDER:1.
 
As used in the Stipulation for Protective Order, these terms have the following meanings:“Attorneys” means counsel of record;“Confidential” documents and information are documents and information designated as such pursuantto paragraph 2;“Documents” are all materials within the scope of Fed. R. Civ. P. 34;“Outside Vendors” means messenger, copy, coding, and other clerical-services vendors not employed bya party or its Attorneys; and “Written Assurance” means an executed document in the form attached as Exhibit A.2.
 
A Party may designate a document or other information produced during discovery or in Fed. R.Civ. P. 26 disclosures as “Confidential,” to protect information within the scope of Fed. R. Civ. P. 26 (c).3.
 
A party may designate Confidential documents or information by:a.
 
imprinting the word “Confidential” on the first page or cover page of any document produced; b.
 
imprinting the word “Confidential” next to or above any answer to an interrogatory;c.
 
advising the court reporter that certain testimony is Confidential and is to be separatelytranscribed and marked accordingly; or d.
 
informing all other counsel, in writing, that certain information is Confidential and isgoverned by the Protective Order.
CASE 0:12-cv-01958-SRN-AJB Document 58 Filed 06/06/13 Page 2 of 8
 
3.4.
 
All Confidential documents received by the opposing party in discovery, along with theinformation contained in the documents (unless the information is also secured by that opposing party from analternative source), shall be used solely for the purpose of this action, and no person receiving such documentsshall, directly or indirectly, use, transfer, disclose, or communicate in any way the documents or their contentsto any person other than those specified in paragraph four (5). Any other use is prohibited. All documents produced as a result of the Plaintiff executing medical authorizations shall be deemed “Confidential.”5.
 
Any Confidential document shall not be given, shown, made available, or communicated in anyway to anyone other than:a.
 
the Court and its staff; b.
 
Attorneys, their law firms, and their Outside Vendors;c.
 
 persons shown on the face of the document to have authored or received it;d.
 
court reporters retained to transcribe testimony;e.
 
the parties;f.
 
outside independent persons (i.e., persons not currently or formerly employed by,consulting with, or otherwise associated with any party) who are retained by a party or itsAttorneys to provide assistance as mock jurors or focus group members or the like, or tofurnish technical or expert services, and/or to give testimony in this action.g.
 
such other persons as the Court may specifically approve after notice and hearing; and h.
 
such other persons as the parties may agree in writing.6.
 
Third parties producing documents in the course of this action may also designate documents as“Confidential,” subject to the same protections and constraints as the parties to the action. A copy of theProtective Order shall be served along with any subpoena served in connection with this action. All documents produced by such third parties shall be treated as “Confidential” for a period of 14 days from the date of their  production, and during that period any party may designate such documents as “Confidential” pursuant to theterms of the Protective Order.7.
 
Each person appropriately designated pursuant to paragraph (5)(f) to receive Confidentialinformation shall execute a “Written Assurance” in the form attached as Exhibit A. Opposing counsel shall be
CASE 0:12-cv-01958-SRN-AJB Document 58 Filed 06/06/13 Page 3 of 8

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