Gardner v. University of Connecticut Health Center

Filing 26

RULING (see attached) granting the parties' 25 Joint Motion for Protective Order and approving and entering their proposed [Doc. 25 -1] Joint Protective Order. Signed by Judge Charles S. Haight, Jr. on November 18, 2013.(Dorais, L.)

Case 3:12-cv-01168-CSH Document 25-1 Filed 11/06/13 Page 1 of 3

UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

ERIN GARDNER
Plaintiff
v.
UNIVERSITY OF CONNECTICUT
HEALTH CENTER
Defendant

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CIVIL ACTION NO. 3:12CV1168(CSH)

November 6, 2013

JOINT PROTECTIVE ORDER
1) The use of all disks provided by defense counsel to plaintiff’s counsel, his staff
or experts which show or depict any inmate and any part of the inside or outside
of a Connecticut Correctional Institution (“disks”) shall consist of and be limited
to disclosure to:
a) Counsel of record for the named plaintiff and defendants;
b) The paralegal, clerical and secretarial staffs employed by counsel
referenced in section a above;
c) Experts, investigators, and consultants retained by counsel in
connection with any litigation arising from this incident;
d) This Court;
e) Any court reporter present in his or her official capacity at any hearing,
deposition or other proceeding in this action;
f) The plaintiff while she is in the presence of her counsel, Attorney
Thomas Bucci
g) Witnesses at deposition and trial.
2) That any person to whom the disks are to be disclosed subject to the Protective
Order shall be informed of the contents of the Protective Order prior to said
disclosure and shall agree in writing, or by statement recorded in a written
transcript of proceedings, to be bound by its terms.
3) Plaintiff, her attorneys, agents, employees, and/or experts are expressly
prohibited from copying said disks without prior written approval of the Court
and all copies of the disks shall be returned to defense counsel at the conclusion
of the case;

Case 3:12-cv-01168-CSH Document 25-1 Filed 11/06/13 Page 2 of 3

4) Any party may seek a modification of the Protective Order based upon a
showing of good cause that the modification is necessary to further this pending
court proceeding only. In the event such a motion is made, the identity of any
person to whom disclosure of information is sought shall be included within the
motion, along with the reason or reasons that disclosure of protected information
is necessary to advance this litigation. Such disclosure of identity may be made to
the court in camera.
5) Nothing in this Protective Order waives any party’s right to object to the
admissibility of the disks at trial in this or any other proceeding.
6) Prior to filing said disks with the court and/or moving for their introduction
into evidence, both parties will jointly request that the disks be filed under seal.

By Order of the Court this _____ day of __________________, 2013
18th
November

BY:

_______________________________
/s/Charles S. Haight, Jr.

Senior United States District Court Judge

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Case 3:12-cv-01168-CSH Document 25-1 Filed 11/06/13 Page 3 of 3

PLAINTIFF,
ERIN GARDNER
By: ____/s/ Thomas W. Bucci_______
Thomas W. Bucci
WILLINGER, WILLINGER
& BUCCI, P.C.
855 Main Street
Bridgeport, CT 06604
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Federal Bar # ct07805
DEFENDANT,
UNIVERSITY OF CONNECTICUT
HEALTH CENTER
By:___/s/ Carolyn Ennis__________
Carolyn Ennis
Assistant Attorney General
55 Elm Street, P. O. Box 120
Hartford, CT 06141-0120
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]
Federal Bar # ct28485
CERTIFICATION
I hereby certify that on November 6, 2013, a copy of the foregoing Proposed Joint
Protective Order was filed electronically. Notice of this filing will be sent by e-mail to all parties
by operation of the Court’s electronic filing system. Parties may access this filing through the
Court’s system.

______________________________
Carolyn Ennis (# ct28485)
Assistant Attorney General
4226842

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