Phillips v. Blair et al

Filing 11

STIPULATED PROTECTIVE ORDER. Signed by Magistrate Judge Terence P. Kemp on 2/8/2017. (agm)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
DALE PHILLIPS,

:

Plaintiff,

:

v.

:

KAREN BLAIR, et al.

Case No. 2:16-CV-880
Judge Marbley
Magistrate Judge Kemp

:

Defendants.

:

STIPULATED PROTECTIVE ORDER
In connection with the claims made by Plaintiff in the above-referenced litigation, the
parties anticipate that Defendants will seek production of Plaintiff’s medical records. In
anticipation that such records will be requested and produced, the Court makes the following
order:
1. This Order covers all medical and mental health records produced for Plaintiff Dale
Phillips in connection with the above-referenced litigation.  
2. All Plaintiff’s medical and mental health care records produced in connection with this
litigation will be used for purposes of this litigation only. 
3. Plaintiff’s medical and mental health care records will be released only to Defendants’
counsel, Paula J. Lloyd and Pamela J. Gordon and/or their authorized agents, namely
staff of counsel’s office.  
4. Defendants’ counsel shall maintain Plaintiff’s medical and mental health care records so
as to protect the confidential nature of the information.  
5. If Defendants’ counsel intends to give copies of Plaintiff’s medical or mental health care
records to any person outside office staff, Defendants’ counsel will require, prior to

disclosure, that such person execute the Agreement attached hereto as Exhibit A. The
signed Agreement shall be maintained by Defendants’ counsel until the conclusion of this
action.  
6. Upon final adjudication of this matter, Defendants’ counsel and any person to whom
copies of Plaintiff’s medical or mental health records have been given, shall destroy all
copies of the medical and mental health care records.  
7. This Order does not govern the use of Plaintiff’s medical and/or mental health care
records at trial. 
IT IS SO ORDERED.

/s/ Terence P. Kemp
United States Magistrate Judge

DALE PHILLIPS,

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
Exhibit A to Stipulated
Protective Order
:

Plaintiff,
v.

:
:

KAREN BLAIR, et al.
Defendants.

Case No. 2:16-CV-880
Judge Marbley
Magistrate Judge Kemp

:
:

ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
BY STIPULATED PROTECTIVE ORDER
The undersigned hereby acknowledges that he/she has read the Stipulated Protective
Order in the above-referenced litigation, which covers Plaintiff’s medical and mental health care
records. The undersigned understands that such records are to be used only for the purposes of
the instant litigation. The undersigned agrees not to provide copies of the medical and mental
health care records, received from Defendants’ counsel, to any other person and further agrees to
destroy copies of Plaintiff’s medical and mental health care records at the conclusion of the
above-referenced litigation.
Date:_______________________

Signature: ________________________________