Ribeiro et al v. Baby Trend, Inc.

Filing 39

STIPULATED PROTECTIVE ORDER entered pursuant to the parties' Stipulation for Protective Order 38 . Ordered by Magistrate Judge F.A. Gossett. (JSF)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
FRANCO RIBEIRO and DEANNA
RIBEIRO, as individuals and as next
friends and biological parents of
LUCAS RIBEIRO, an infant,
Plaintiffs,
vs.
BABY TREND, INC.,
Defendant.

)
)
)
)
)
)
)
)
)
)
)
)

CASE NO. 8:12cv204

STIPULATED
PROTECTIVE ORDER

Pursuant to the parties’ Stipulation for Protective Order (filing 38),
IT IS HEREBY ORDERED:
a. That all documents and information responsive to Plaintiffs’ requests for
production of documents, requests 1 through 12, inclusive shall be considered
“Confidential Documents” and “Confidential Information” and disclosed only to
the parties to this litigation, the attorneys for the parties, consultants or experts
specially retained or specially employed for purposes of this litigation and
maintained and retained in accordance with subparagraph (d) below.

All

“Confidential Documents” and “Confidential Information” to include documents
and information disclosed in digital formats such as CD’s and DVD’s shall be
labeled and identified as “Confidential and Restricted Subject to Stipulated
Protective Order.”

b. The parties and their consultants or experts specially retained or specially
employed for purposes of this litigation are to use Confidential Documents and
Confidential Information solely and exclusively in connection with this litigation.
c. No copies of any Confidential Documents or Confidential Information disclosed
will be made except as necessary for the purposes of the litigation. It if becomes
necessary to use such Confidential Documents and Confidential Information in
any filing with this Court, then any such filing shall be made under seal.
d. Upon resolution of this litigation, all documents disclosed pursuant to this Order,
and all copies thereof, shall be destroyed or returned to the producing party by the
party in possession of the documents. To the extent any such documents were
used by the parties’ consultants or experts specially retained or specially employed
for purposes of this litigation, as allowed under this Order, each expert witness or
consultant shall be advised of the provisions of this Order, and destroy, purge or
return all documents to the producing party upon conclusion of the litigation.
This Stipulated Protective Order shall protect trade secrets, confidential research,
development and commercial information, while allowing Plaintiffs necessary freedom to
investigate, review and analyze documents and information relevant to Defendant’s
infant car seats subject to product liability theories in the subject litigation.
DATED April 23, 2013.
BY THE COURT:

S/ F.A. Gossett
United States Magistrate Judge
2