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Lane v. Philbin

United States District Court, M.D. Georgia, Valdosta Division

December 8, 2017

RODNEY M. LANE, Plaintiff,
v.
TED PHILBIN, et al., Defendants.

          STIPULATED PROTECTIVE ORDER

          HUGH LAWSON, SENIOR JUDGE

         THE COURT ALERTS THE PARTIES THAT IT HAS ADDED A FINAL PARAGRAPH TO THIS PROTECTIVE ORDER THAT WAS NOT INCLUDED IN THE STIPULATED ORDER SUBMITTED TO THE COURT.

         WHEREAS any discovery material (defined below) in this lawsuit may involve the production or disclosure of confidential institutional or medical records or private health-related information (“Confidential Information”); and

         WHEREAS counsel for the parties have consented to entry of this Order; IT IS HEREBY ORDERED:

         1. As used in this Protective Order (the “Order”), the term “discovery material” shall encompass all information contained in documents, computer data and reports, deposition testimony and exhibits, interrogatory answers, responses to requests for admission, pleadings, motions, briefs, affidavits, and any other written, recorded, computerized, electronic, transcribed or graphic matter produced by any party or obtained by any party during discovery in this suit, and any copies thereof. Plaintiff and Defendants are referred to herein as “the Parties.” “Producing party” and “designating party” may include any person, whether or not a party, who provides discovery material. “Receiving party” may include any person, whether or not a party, who received discovery material. “Suit” means the above-styled lawsuit pending in the Middle District of Georgia, Valdosta Division.

         2. This Order is binding upon the Parties to the Suit, their respective attorneys, agents, representatives, officers and employees and others as set forth in this Order.

         3. The Parties shall have the right, in good faith, to designate material that has been or will be made available in this suit as Confidential Information by affixing in a conspicuous place on the discovery material the label “CONFIDENTIAL.” A party shall make such designation only with respect to discovery materials revealing non-public, confidential information not known to the general public.

         4. The Parties, their attorneys, or anyone else acting on their behalf shall take such precautions with the Confidential Information as are necessary to strictly maintain its confidentiality and comply with the terms of this Order. Discovery material designated “CONFIDENTIAL” may be inspected and disclosed only to the following persons:

a) The parties, including the directors, officers and employees of the parties to the Suit and their affiliates, and counsel for the parties to this Suit, including inside counsel of any party who is assisting in the preparation of that party's case;
b) Employees of such counsel engaged in assisting counsel in the preparation of this Suit including secretaries and paralegal assistants;
c) Court officials involved in the Suit, including court reporters and persons operating video recording equipment at depositions;
d) Witnesses, provided that (1) discovery material is used in connection with the examination of the witness; (2) counsel using such documents or information believes in good faith that such use is necessary or appropriate; and (3) the witness is first provided with a copy of this Order and executes Exhibit A, or is the author, recipient or a copyee of such discovery material;
e) Independent contractors, outside consultants, and experts, and their staff, consulted or retained by a party for the purpose of assisting in the prosecution or defense of the Suit, provided that such persons shall be given a copy of this Order, advised that they are bound by it, and sign Exhibit A; and
f) Any other person who is designated as an authorized person by an Order of this Court, after notice to the parties, or by ...

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