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Kent v. Winchester Hospital

United States District Court, D. Massachusetts

December 12, 2017

DEBRA KENT, Plaintiff,
v.
WINCHESTER HOSPITAL, Defendant.

          CONFIDENTIALITY STIPULATION AND PROTECTIVE ORDER

         Pursuant to Fed.R.Civ.P. 26(c), IT IS HEREBY STIPULATED AND AGREED TO by the undersigned counsel for Plaintiff and Defendant that the following provisions shall govern the disclosure and use of all documents, testimony, and other information designated as “Confidential” or “Confidential - Attorneys' Eyes Only” that is produced or given by any Party in the course of discovery in this action.

         ACCORDINGLY, IT IS HEREBY STIPULATED AND AGREED TO that:

         1. “Party” or “Parties, ” as used herein, means Plaintiff Debra Kent and Defendant Winchester Hospital, as represented by their respective counsel.

         2. The term “Information, ” as used herein, shall include any document, testimony, electronic data, interrogatory response, response to requests for admissions, or other information disclosed or produced by or on behalf of a Party (or any of his or its attorneys or other agents) or by or on behalf of a third party from whom discovery is sought, and all documents incorporating such information.

         3. “Confidential Information, ” as used herein, means all personal, medical, personnel, employee, proprietary, financial, business or other commercially sensitive information, whether documentary or otherwise, designated as “Confidential” and delivered or produced by any Party or third-party witness in response to a request for production of documents, subpoena, or otherwise. The designation of Information as “Confidential Information” shall be applied only to Information that the Party or third party producing or providing the Information (a) has a good faith interest in preserving as confidential, or (b) has a legal responsibility to another person or entity to preserve the private, confidential, or proprietary nature of the Information. Any Information that is readily available or generally known to the public shall not be considered or designated as “Confidential Information.”

         4. “Confidential - Attorney's Eyes Only, ” as used herein, means all highly confidential, proprietary, or personal Information that may require special handling in addition to the procedures required for handling “Confidential Information.” It is the intent of the Parties that the “Confidential -Attorney Eyes Only” designation shall be reserved for Information that is highly personal or highly proprietary, technical or business information relating to present or planned activities of the designating Party or third party that has been and is being maintained in confidence by the designating Party or third party. If only a portion of a document, an interrogatory response, or deposition testimony contains information that is properly designated as “Confidential - Attorneys' Eyes Only, ” then the designating Party shall clearly designate which portion(s) of the document, interrogatory response, or deposition testimony contains information that is to be treated as “Confidential - Attorneys' Eyes Only.”

         5. To the extent that documents are designated “Confidential - Attorneys' Eyes Only, ” counsel may nonetheless disclose the documents to the Parties with the “Confidential - Attorneys' Eyes Only” portion(s) of the document redacted. In the event that counsel intend to disclose such redacted documents to the Parties, they shall provide the proposed redacted documents to the designating Party for its review. The designating Party shall, within five (5) business days of the actual receipt of the proposed redacted document, communicate its agreement that the redacted version of the document may be disclosed to the Parties, or it may provide an alternate redacted version of the document that it agrees may be disclosed to the Parties.

         6. All Information produced in this action, whether or not designated as “Confidential” or “Confidential - Attorneys' Eyes Only, ” shall be used by the Party receiving such information solely in connection with this litigation.

         7. Except with the prior consent of the designating Party or upon prior order of the Court, Information designated as “Confidential” shall not be disclosed by any Party to any person other than the following:

(a) counsel of record for the Parties in this litigation, the Parties' in-house attorneys, and the paralegals, secretaries, legal assistants, and other similar support personnel of the Parties or their counsel of record, as reasonably necessary to assist the Parties' counsel of record and in-house attorneys in this litigation;
(b) outside experts, consultants, and litigation support vendors who are not employees of any Party and who are expressly retained to assist counsel of record for the Parties and the employees of such persons;
(c) the Court, Court personnel, and jurors;
(d) court reporters and videographers who are retained to transcribe or videotape testimony in this action;
(e) the Parties and their officers, solely for the purpose of prosecuting, defending, or ...

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