Kiehl v. Board of County Commissioners for Sumner County, Kansas et al

Filing 29

AGREED PROTECTIVE ORDER. Signed by Magistrate Judge James P. O'Hara on 12/13/2010. (ah)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS STEPHANIE KIEHL, ) ) Plaintiff, ) ) vs. ) ) THE BOARD OF COUNTY ) COMMISSIONERS OF SUMNER COUNTY, ) KANSAS, and PROGRESSIVE DIRECT ) INSURANCE COMPANY, a foreign ) corporation, ) ) Defendants. ) _______________________________________)

Case No. 10-1252-KHV-JPO

AGREED PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION NOW, on this 13th day of December 2010, the Court hereby enters a protective order pursuant to Fed. R. Civ. P. 26(c). This case arises out of a motor vehicle accident that occurred involving plaintiff and H. Lloyd Kromka, who was acting in the course and scope of his employment with Sumner County, Kansas. Plaintiff alleges Kromka acted negligently thereby causing the motor vehicle accident. These claims may lead to discovery of personnel files or records of H. Lloyd Kromka which are ordinarily deemed confidential. On joint motion of the parties and for good cause shown, the Court orders that any such documents produced or disclosed during this litigation shall be used only for purposes of this lawsuit.

The Court further orders:

1.

That access to said personnel files or records of Kromka obtained under this

Protective Order shall be limited to the parties, their counsel, clerical and staff persons employed by counsel, expert witnesses, and the Court; 2. this case; 3. That such confidential documents may be filed under seal only upon separate, That their use shall be restricted to pretrial, trial, and appellate proceedings in

specific motion and later order of the Court; 4. That within thirty (30) days after the conclusion of this litigation, all copies of

the confidential documents produced under this Protective Order shall either be destroyed or returned to the respective parties' counsel. IT IS SO ORDERED.

Dated December 13, 2010, at Kansas City, Kansas. s/James P. O'Hara James P. O'Hara U.S. Magistrate Judge
APPROVED: s/Brooks Kancel Brooks Kancel, #10473 Fleeson, Gooing, Coulson & Kitch, L.L.C. 1900 Epic Center, 301 N. Main Wichita, Kansas 67202 Tel: [phone] Fax: [phone] Email: [e-mail] Attorneys for Defendant, The Board of County Commissioners of Sumner County

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s/ Bradley Pistotnik Bradley A. Pistotnik, #10626 Affiliated Attorneys of Pistotnik Law Offices, P.A. 2831 E. Central Wichita, Kansas 67214 Tel: [phone] Fax: [phone] Email: [e-mail] Attorneys for Plaintiff

s/ Jennifer M. Hill Kevin McMaster, #11903 Jennifer M. Hill, #21213 Attorneys for Defendants MCDONALD, TINKER, SKAER, QUINN & HERRINGTON, P.A. 300 West Douglas, Suite 500 P.O. Box 207 Wichita, KS 67201-0207 Telephone: [phone] Facsimile: 316-263-4677 E-mail: [e-mail] [e-mail]

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