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Stipulated Protective Order

Stipulated Protective Order

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Published by Chad Brewbaker
Tom Miller's protective order to stonewall the public from viewing discovery documents in Smith v Regents.
Tom Miller's protective order to stonewall the public from viewing discovery documents in Smith v Regents.

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Published by: Chad Brewbaker on Dec 17, 2011
Copyright:Public Domain


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IN THE IOWA DISTRICT COURT IN AND FOR STORY COUNTY _____________________________________________________________________ DENNIS L. SMITH, ) Law No. LACV045119) Law No. LACV046341Plaintiff, ))vs. ))IOWA STATE BOARD OF REGENTS, )
SCIENCE AND TECHNOLOGY, )AND PAMELA REINIG, ))Defendants. ) _____________________________________________________________________ 
Plaintiff and Defendants jointly agree to the following protective order to limit thedisclosure of certain information.The parties acknowledge that records of persons not party to this lawsuit will be disclosedduring the course of discovery and any trial in this case. The parties are also aware of thesensitive and confidential nature of some of the records in this case. In order to limit thedissemination of such information,IT IS HEREBY ORDERED THAT:1. This protective order governs the treatment of all documents, depositiontranscripts, deposition exhibits, interrogatory answers, responses to requests for admission, andother written, recorded, computerized, electronic or graphic material, copies, excerpts, or summaries of documents produced or provided in discovery in this case and designated by a
 party as a confidential document pursuant to the terms of this Order (collectively, “ConfidentialDiscovery Material”). Prior to designating any material as Confidential Discovery Materialhereunder , the designating party must make a determination that good cause exists to designatethe material as confidential. A party may only make such designations with respect to materialsit produced and may not make such designations with respect to materials produced by another  party or a nonparty.2. All Confidential Discovery Material shall be used by the parties solely for the purpose of preparation, trial, appeal, or settlement of this litigation and for no other purposewhatsoever and shall not be used by, or disclosed to, any person except Qualified Persons asdefined below, except by order of this Court. The parties specifically agree that they shall not post or refer to the Confidential Discovery Materials on a website, blog or other social media siteor provide the Confidential Discovery Materials to others for the purpose of doing so. The partiesspecifically agree not to post Confidential Discovery Materials received by another party indiscovery, and not already in their possession to any blog. The plaintiff agrees not to provide anyConfidential Discovery Materials produced by Iowa State University and not already in his possession, to Chad Brewbaker.3. “Qualified persons,” as used herein, means:a)
Attorneys of record and employees of such attorneys whose access to theConfidential Discovery Material is necessary for purposes of trial, preparation,appeal, or settlement of this litigation;
Independent third parties retained or used by attorneys of record in this litigationsolely for the purposes of trial, preparation, appeal or settlement of this litigation;
 Named parties and employees, or former employees, of parties, who are working onthis litigation and to whom it is necessary that the Confidential Discovery Material beshown for purposes of trial, preparation, appeal or settlement of this litigation;
Court reporters employed for this litigation;
Any other person who is designated as a Qualified Person by written agreement of the parties, or by Order of this Court.
4. In the event that any of the parties disagree with the designation of anyinformation as Confidential, or the designation of any person as a Qualified Person, the partiesshall first try to resolve the dispute in good faith on an informal basis. If the dispute cannot beresolved, the objecting party may seek appropriate relief from the court. The parties may, by joint written stipulation, provide for exceptions to this Order. Any party, after notice to all parties, may seek an order of the court modifying this order. This order shall be without prejudice to any party to bring before the court at any time the question of whether any particular Confidential Discovery Material can be disclosed beyond the scope of this Protective Order. The party that designated the material as Confidential Discovery Material shall have the burden of  proving by a preponderance of the evidence that there is good cause for continued protectionunder the terms of this Order.5. Within 60 days of the conclusion of this litigation all Confidential DiscoveryMaterial, including deposition transcripts, and all photocopies or other copies thereof, shall bereturned to the party who disclosed, produced, or provided the same, except as this Court mayotherwise order or as the parties may otherwise agree in writing.

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