Perinatal Medical Group, Inc., et al. v. Children's Hospital Central CA, Inc.

Filing 47

STIPULATION Concerning Documents Marked Confidential/Attorney's Eyes Only and ORDER thereon, signed by Magistrate Judge Sandra M. Snyder on 3/29/2010. (Herman, H)

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Clark Stanton #60374 Thomas R. Burke #141930 Gwen Fanger #191161 DAVIS WRIGHT TREMAINE LLP 505 Montgomery Street, Suite 800 San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] William C. Hahesy, #105743 LAW OFFICES OF WILLIAM C. HAHESY 225 West Shaw Avenue, Suite 105 Fresno, CA 93704 Telephone [phone] Facsimile [phone] Email: [e-mail] Attorneys for Defendant, CHILDREN'S HOSPITAL CENTRAL CALIFORNIA, INC.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA PERINATAL MEDICAL GROUP, INC., KRISHNAKUMAR RAJANI, M.D., and STEPHEN ELLIOT, M.D. Plaintiffs, v. CHILDREN'S HOSPITAL CENTRAL CALIFORNIA,INC., a California Corporation, Defendant. STIPULATION 1. The parties have entered into a Stipulated Protective Order that was filed after Case No.1:09-CV-01273 LJO SMS STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENTIAL/ATTORNEY'S EYES ONLY AND ORDER THEREON

signature by this Court on January 11, 2010. ///
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STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENTIAL/ATTORNEY'S EYES ONLY AND [PROPOSED] ORDER THEREON PDF created with pdfFactory trial version www.pdffactory.com

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In connection with discovery in this case, the Plaintiff has produced to

Defendant Children's Hospital Central California certain documents marked "PMG03341339", all of which have been marked "attorney's eyes only." 3. 4. Defendant Children's Hospital Central California disputes this designation. In an attempt to resolve this dispute informally, the parties agreed that

compilations and summaries relating to those documents prepared either by counsel or others retained by counsel (so long as not employed by Defendant Children's Hospital Central California or other defendants), could be shared with the Hospital's CEO, CFO Todd Suntrapak, in-house counsel, Mr. Richard Wolf, and insurance representatives, so long as those persons agreed that such information would not be shared with others unless the persons are those who are identified in Section 7 of the Stipulated Protective Order. 5. The parties desire to memorialize that agreement for purposes of the actual

litigation to permit counsel for Defendant Children's Hospital Central California to share compilations and summaries from those documents but not the actual documents themselves, with the personnel identified in paragraph 4 above, the Hospital's in-house counsel, Mr. Richard Wolf, and insurance representatives, so long as those persons agree that information will not otherwise be disclosed to anyone other than the persons referenced in Section 7 of the Stipulated Protective Order. 6. The parties have agreed that the time period to challenge this designation shall

be waived as it relates to these documents and that the provisions of paragraph 5 of the Stipulated Protective Order shall not apply to this designation. Defendant Children's Hospital Central California shall have the opportunity at any time in the future during the course of this case to challenge this designation if it so desires, including seeking the ability to share certain documents with the client or other persons. DATED: ___3/18/10____ By: __/s/ WILLIAM C. HAHESY__________ William C. Hahesy, Attorneys for Defendant, CHILDREN'S HOSPITAL CENTRAL CALIFORNIA
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STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENTIAL/ATTORNEY'S EYES ONLY AND [PROPOSED] ORDER THEREON PDF created with pdfFactory trial version www.pdffactory.com

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DATED: ___3/19/10_____

CHRISTENSEN & AUER By: __/s/ STEPHEN AUER_____________ Stephen Auer, Attorneys for Plaintiffs

DATED: __ 3/19/10______

DAVIS WRIGHT TREMAINE, LLP By:__/s/ WILLIAM C. HAHESY for_____ Douglas Ross Attorneys for Defendant, CHILDREN'S HOSPITAL CENTRAL CALIFORNIA

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STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENTIAL/ATTORNEY'S EYES ONLY AND [PROPOSED] ORDER THEREON PDF created with pdfFactory trial version www.pdffactory.com

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA PERINATAL MEDICAL GROUP, INC., KRISHNAKUMAR RAJANI, M.D., and STEPHEN ELLIOT, M.D. Plaintiffs, v. CHILDREN'S HOSPITAL CENTRAL CALIFORNIA,INC., a California Corporation, Defendant. The Court having reviewed the foregoing stipulation and good cause appearing therefor: IT IS SO ORDERED. Dated: March 29, 2010 /s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE Case No.1:09-CV-01273 LJO SMS ORDER ON STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENITAL/ATTORNEY'S EYES ONLY

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STIPULATION CONCERNING DOCUMENTS MARKED CONFIDENTIAL/ATTORNEY'S EYES ONLY AND [PROPOSED] ORDER THEREON PDF created with pdfFactory trial version www.pdffactory.com