Eddy v. Bellevue Berry Farms, Inc. et al

Filing 50

PROTECTIVE ORDER - the parties have approved this Order as shown by the signatures indicating approval of the contents of this Order. Ordered by Magistrate Judge Michael D. Nelson. (LKO)

8:18-cv-00221-MDN Doc # 50 Filed: 06/01/20 Page 1 of 2 - Page ID # 190

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
SANDRA L. EDDY,
Plaintiff,

8:18CV221

vs.

PROTECTIVE ORDER

BELLEVUE BERRY FARMS, INC.,
EDWARD A. SCHAEFER A TRUSTEE
LIVING TRUST, and DOES 1-5,
Defendants.

This matter comes before this Court at the request of the parties in this action.
WHEREAS, Plaintiff is seeking discovery of financial information from the Defendants.
WHEREAS, Defendants contend that such information is confidential and should not be
shared outside of this litigation.
WHEREAS, the parties have approved this Order as shown by the signatures indicating
approval of the contents of this Order.
IT IS THEREFORE ORDERED AS FOLLOWS:
1. The parties agree that any exhibits produced at the Rule 36(b) deposition of a representative
of Defendant shall be marked as confidential. Such exhibits will include financial records of
any nature representing the financial condition of Defendant and its shareholders and
officers. That testimony taken during this deposition will be designated as confidential.
2. Such records will be placed under restricted access with the Court for any pretrial
proceedings. These records can be used at trial and disclosed to the jury, if otherwise
admissible.
3. The parties shall be allowed to share such information with any expert witnesses consulted or
retained by the parties. The parties shall advise the expert witness of this Order and that such
information is to remain confidential.
4. The Parties shall not disclose the information described above to any persons or entities who
are not involved in this litigation.

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8:18-cv-00221-MDN Doc # 50 Filed: 06/01/20 Page 2 of 2 - Page ID # 191

5. Within 30 days of final resolution of this matter (whether by settlement or trial, including any
appeals) the parties shall destroy the exhibits.
Dated this 1st day of June, 2020.
BY THE COURT:
s/Michael D. Nelson
United States Magistrate Judge
APPROVED AS TO CONTENT AND FORM:
BY:

/s/Raymond R. Aranza, #18523
Raymond R. Aranza, #18523
Richard C. Gordon, #11549
Jonathan M. Brown, #25021
WALENTINE O’TOOLE, LLP
11240 Davenport Street
P. O. Box 540125
Omaha, NE 68154
Phone: [phone] Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
ATTORNEYS FOR BELLEVUE BERRY FARMS,
INC.; EDWARD A. SCHAEFFER A TRUSTEE
LIVING TRUST, Defendants

BY:

/s/Justin High, #23354
Justin High, #23354
High & Younes
6919 Dodge Street
Omaha, Nebraska 68132
Ph: 402-933-3345
Fax: [phone]
[e-mail]
Ross Pesak
Pesak Law
4826 S. 24th Street
Omaha, NE 68107
Phone: [phone]
Fax: [phone]
[e-mail]
ATTORNEYS FOR SANDY L. EDDY,
PLAINTIFF
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