Dmondi v. Cardinal Health 414, LLC

Filing 18

STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge David Keesler on 4/13/12. (com)

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NORTH CAROLINA
CHARLOTTE DIVISION
CIVIL ACTION NO. 3:11-CV-87-DCK

RUTH DMONDI,

)
)
Plaintiff,
)
)
v.
)
)
CARDINAL HEALTH 414, LLC, a/k/a )
CARDINAL HEALTH 414, INC.,
)
)
Defendant.
)
___________________________________ )
STIPULATED PROTECTIVE ORDER
Plaintiff Ruth Dmondi and Defendant Cardinal Health 414, LLC hereby stipulate and agree
as follows, and further request that the Court sign this Stipulated Protective Order:
1.

The parties anticipate that discovery in this matter may include medical,

psychological, health, pharmaceutical, or mental health records, as well as tax records, related to the
plaintiff or possibly other individuals. For purposes of this Protective Order, all such information
shall be deemed “Protected Information.”
2.

Protected Information that is received by a party solely because it has been produced

by the other party or by a nonparty during this litigation shall not be used by the receiving party for
any purpose other than the above-captioned litigation or any related legal proceeding or appeal. At
the conclusion of this litigation or of any related legal proceeding or appeals, all such Protected
Information (including all copies thereof) shall be destroyed or returned to the entity that provided
it, or otherwise disposed of in accordance with the final order of the Court.
3.

Protected Information that was already accessible to a party before this litigation

began or that was already in a party’s possession before this litigation began or that relates to a party

(regardless of when the information was obtained) shall not be subject to the restrictions in section
2 for that particular party.
STIPULATED TO AND AGREED BY:
s/Geraldine Sumter
Geraldine Sumter
North Carolina State Bar No. 11107
Email: [e-mail]
For the law firm of
FERGUSON STEIN CHAMBERS
GRESHAM & SUMTER, PA
741 Kenilworth Ave., Suite 300
Charlotte, NC 28204
[phone]
[phone] fax
Attorneys for Plaintiff

s/Jeremy R. Sayre
Jeremy R. Sayre
North Carolina State Bar I.C. 32164
Email: [e-mail]
For the law firm of
WARD AND SMITH, P.A.
Wade II, Suite 400
5430 Wade Park Boulevard
Raleigh, North Carolina 27607
[phone]
[phone] fax
s/Todd H. Lebowitz
Todd H. Lebowitz (pro hac vice)
Email: [e-mail]
for the law firm of
BAKER & HOSTETLER LLP
PNC Center
1900 East Ninth Street, Suite 3200
Cleveland, Ohio 44114-3482
[phone]
[phone] fax
Attorneys for Defendant

IT IS SO ORDERED.
Signed: April 12, 2012

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CERTIFICATE OF SERVICE
I hereby certify that on April 11, 2012, the foregoing was electronically filed and served via
the Court’s ECF system upon counsel for plaintiff:
Geraldine Sumter
FERGUSON STEIN CHAMBERS GRESHAM & SUMTER, PA
741 Kenilworth Ave., Suite 300
Charlotte, NC 28204

s/Jeremy Sayre
Jeremy Sayre

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