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Taylor v. Rebound Behavioral Health, LLC

United States District Court, D. South Carolina, Rock Hill Division

February 1, 2017

Leslie Taylor, Plaintiff,
v.
Rebound Behavioral Health, LLC, Defendant.

          STIPULATED PROTECTIVE ORDER

          Paige J. Gossett UNITED STATES MAGISTRATE JUDGE

         Whereas, each of the Parties to the above captioned action may seek discovery of documents, information or other materials which may contain or relate to confidential, proprietary or trade secret information of another party or of a third party;

         Whereas, the Parties have in good faith conferred and have agreed upon the terms of a Protective Order and for good cause shown; therefore, The Parties stipulate, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, subject to the approval of the Court, to the following Protective Order:

         1. This Protective Order shall govern certain designated information that is produced by any of the parties in this action, whether produced in response to formal or informal discovery requests or in compliance with the Federal Rules of Civil Procedure or produced voluntarily in support of any claim or defense in this action, including (but not limited to) such information contained in documents, interrogatory responses, testimony (whether at trial, at deposition or in a written declaration or affidavit), responses to requests for admission, initial disclosures, expert reports or other expert-related materials.

         2. Any of the parties may designate material or information disclosed or produced in this action as “Confidential” or as “Attorney's Eyes Only.” 3. Any of the parties producing Confidential or Attorney's Eyes Only material or information may designate such material or information by:

         (a) With regard to documents, responses to discovery requests and tangible objects, the producing party may affix (as by writing, stamping, labeling or the like) to the page or item containing or disclosing the confidential or attorneys-eyes-only information the term “CONFIDENTIAL” or “ATTORNEY'S EYES ONLY” as appropriate, or words to that effect; or by providing written notice to all other parties in the action, before or at the time of production of such materials, that adequately describes the materials in question and whether those materials should be treated as “confidential” or “attorney's eyes only.”

         (b) With regard to information disclosed at a deposition, the producing party may designate such information as “confidential” or “attorneys' eyes only, ” as appropriate, by so indicating on the record at the deposition the testimony to which the designation applies; or by notifying the court reporter and all parties to this action, within thirty (30) calendar days of receipt of the deposition transcript, of the portions of the testimony that should be designated as “confidential” or “attorney's eyes only.” At the producing party's option, portions of a deposition transcript that have been designated as “confidential” or “attorney's eyes only” may be bound separately from the rest of the transcript and marked as such. A producing party has the right, at the deposition, to have deposition testimony containing “confidential” or “attorney's eyes only” information heard only by those permitted under this Protective Order to have access to such information.

         4. Information designated as “confidential” or “attorney's eyes only” (including but not limited to summaries, abstracts, copies, indices and exhibits) shall be used solely for purposes of this action and shall not be disclosed to anyone other than the persons permitted under this Protective Order.

         5. The Parties shall abide by the confidentiality provisions set forth in the Health Insurance Portability and Accountability Act (“HIPAA”) with respect to the disclosure of any protected health information by any Party or any other person. Protected health information may be designated “confidential.” All materials produced, discovered or otherwise obtained during the course of this litigation containing protected health information shall be used solely for the purposes of this litigation in accordance with the terms of this Order.

         6. Information designated as “attorney's eyes only” (including but not limited to summaries, abstracts, copies, indices and exhibits) shall not be made available and shall not be disclosed to anyone other than the following persons:

         (a) Outside counsel of record working on this action on behalf of any party to this action, together with the assistants, secretaries, paralegals and/or other clerical personnel who are actively assisting such counsel in the preparation of this action;

         (b) Court stenographers, court reporters and their staff; outside deposition video services and their staff, independent contractors and/or third parties engaged to record, transfer and/or store video depositions, provided they execute a Declaration of Compliance in the form and substance as that attached hereto as Exhibit A; outside copy services, translators and graphics or design services, retained or engaged by such outside counsel in connection with their preparation of this action, and only to the extent necessary for such persons to carry out their duties in connection with this action;

         (c) Mock jurors, and jury or trial consulting services, retained or engaged by such outside counsel in connection with their preparation of this action, and only to the extent necessary for such persons to carry out their duties in connection with this action, provided that such persons are furnished with a copy of this Protective Order and execute a Declaration of Compliance in the form and substance as that attached hereto as Exhibit A;

         (d) Mediators who attempt to mediate this action (if any), together with their staff, provided the mediator is furnished with a copy of this Protective Order and executes a Declaration of Compliance in ...


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