Carzoglio v. Paul et al

Filing 34

CONFIDENTIALITY STIPULATION AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... IT IS HEREBY STIPULATED AND ORDERED, PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 26(c), THAT: 1. This P rotective Order shall govern the handling of all information and/or materials produced or disclosed during the course of the Action, by any Party or Non-Party, including but not limited to information produced or disclosed: a. in any pleading, docu ment, affidavit, affirmation, interrogatory answer, responses to requests for admission, brief, motion, transcript, or any other written, electronic, recorded or graphic material; b. in testimony given in a deposition, court hearing, or trial, and any copies, or summaries of such information; or c. through any manner or means of discovery, including the production or inspection of books, records, documents and tangible things, and entry onto any land or premises. 2. As used herein 1 the ter m "Discovery Material" refers to that information and/or materials described in l(a)-(c) above. A Party that designates Discovery Material as Confidential ("Confidential Material") is a "Designating Party." 3. As used herein, "the Action" refers to all proceedings in the above-captioned case, including any appeals and the implementation of any remedy agreed to by the Parties or ordered by the Court. 4. The following documents and information produced or provided by the Parties or Non-Parties during the course of this Litigation, except information which is publicly available, may be designated by any Party as Confidential: a. all documents and information containing personal health or disabil ity information of any Party hereto, including but not limited to documents and information covered by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and records disclosed by a Party pursuant to any Authorizatio n to Release Medical Records executed by the Plaintiff in this Litigation; b. all documents and information containing mental health or psychiatric information of any Party hereto, including but not limited to documents and information covered b y HIPAA and records disclosed by a Party pursuant to any Authorization to Release Psychotherapy Notes executed by the Plaintiff in this Litigation; c. any documents and information which counsel for all Parties agree should be Confidential Materi al, subject to the provisions of paragraph 16 below; d. any other documents and/or information which counsel believes in good faith to be Confidential Material that can be protected from disclosure pursuant to Federal Rule of Civil Procedure 26(c ); e, any Discovery Materials that the Court directs to be produced as Confidential subject to this Order; and f. testimony about the documents and information covered by Paragraph 4(a)-(e). 5. Any summary, compilation, notes, copy, electronic ima ges, or database containing material and/or information designated as "Confidential" shall be subject to the terms of this Protective Order to the same extent as the material or information from which such summary, compilation, notes, elec tronic image, or database is made or derived as further set forth in this order. Clerk of the Court directed to mail a copy of this Order to pro se Plaintiff and show proof of service on the docket. (Signed by Judge Nelson Stephen Roman on 12/10/2019) (rj) Transmission to Docket Assistant Clerk for processing.