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Brown v. Cargill, Inc.

United States District Court, W.D. Wisconsin

August 21, 2017

BRUCE B. BROWN Plaintiff,
v.
CARGILL, INC., CARGILL, INC. d/b/a NUTRENA MILLS, INC., ABC INSURANCE COMPANY, XYZ CORPORATION, and DEF INSURANCE COMPANY, Defendants. and GREAT WEST CASUALTY CO., Involuntary Plaintiff,

          Anthony J. Skemp Counsel for Plaintiff

          David B. Carr Counsel for Defendant

          Eric J. Goelz Counsel for Involuntary Plaintiff

          JOINT STIPULATION

          The Honorable Stephen L. Crocker

         IT IS HEREBY STIPULATED by and between Plaintiff Bruce Brown ("Plaintiff'), Great West Casualty Company ("Involuntary Plaintiff), and Defendants, Cargill, Incorporated, and Cargill, Incorporated d/b/a Nutrena Mills, Inc. ("Defendants, " and with Plaintiff and Involuntary Plaintiff sometimes hereinafter referred to collectively as the "parties"), through their respective attorneys of record, as follows:

         WHEREAS, documents and information have been and may be sought, produced or exhibited by and among the parties to this action falls within one or more of the following categories: (a) information prohibited from disclosure by statute; (b) information that reveals trade secrets; (c) research, technical, commercial or financial information that the Party has maintained as confidential; (d) medical information concerning any individual; (e) personal identity information; (f) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or (g)

         other information that is generally unknown to the public or not readily obtainable from outside sources. Information or documents that are available to the public may not be designated as Confidential.

         THEREFORE, an Order of this Court protecting such confidential information shall be and hereby is made by this Court on the following terms:

         1. This Order shall govern the use, handling, and disclosure of all documents, testimony, or information produced or given in this action which are designated to be subject to this Order in accordance with the terms hereof.

         2. Any party or non-party producing or filing documents or other materials in this action may designate such materials and the information contained therein subject to this Order by typing or stamping on the front of the document, or on the portion(s) of the document for which confidential treatment is designated, "Confidential."

         3. If a producing party believes in good faith that, despite the provisions of this Protective Order, there is a substantial risk of identifiable harm if particular documents it designates as "Confidential" are disclosed to all other parties or non-parties to this action, the Producing Party may designate those Particular documents as "Confidential-Attorneys' Eyes Only."

         4. To the extent any motions, briefs, pleadings, deposition transcripts, or other papers to be filed with the Court incorporate documents or information subject to this Order, the party filing such papers shall designate such materials, or portions thereof, as "Confidential" or "Confidential- Attorneys' Eyes Only, " and shall file them with the clerk under seal; provided, however, that a copy of such filing having the confidential information deleted therefrom may be made part of the public record.

         5. All documents, transcripts, or other materials subject to this Order, and all information derived therefrom (including, but not limited to, all testimony, deposition or otherwise, that refers, reflects, or otherwise discusses any information designated "Confidential" hereunder), shall not be used, directly or indirectly, by any person, including the other Defendant, for any business, commercial or competitive purposes or for any purpose whatsoever other than solely for the preparation and trial of this action in accordance with the provisions of this Order.

         6. Except with the prior written consent of the individual or entity designating a document or portions of a document as "Confidential, " or pursuant to prior Order after notice, any document, transcript, or pleading given "Confidential" treatment under this Order, and any information contained in, or derived from any such materials (including but not limited to, all deposition testimony that refers, reflects, or otherwise discusses any information designated "Confidential" hereunder) may not be disclosed other than in accordance with this Order and may not be disclosed to any person other than: (a) the Court and its officers; (b) parties to this litigation; (c) counsel for the parties, whether retained counsel or in-house counsel and employees of counsel assigned to assist such counsel in the preparation of this litigation; (d) fact witnesses subject to a proffer to the Court or a stipulation of the parties that such witnesses need to know such information; (e) present or former employees of the Producing Party in connection with ...


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