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Schwartz v. American Airlines, Inc.

United States District Court, D. Massachusetts

August 29, 2019

ANDREW SCHWARTZ and AMY SCHWARTZ, Plaintiffs,
v.
AMERICAN AIRLINES, INC. Defendant.

          Respectfully submitted, Defendant American Airlines By counsel: David J. Volkin, Esq. BBO# 630743 The Law Offices of David J. Volkin

          Respectfully submitted, Plaintiffs Andrew Schwartz and Amy Schwartz By counsel: Andrew M. Fischer BBO# 167040 Andrew J. Brodie BBO# 661269 Law Offices of Jeffrey S. Glassman LLC

          ORDER STIPULATION AND PROTECTIVE ORDER GOVERNING DISCOVERY AND THE PROTECTION OF CONFIDENTIAL INFORMATION

          Hon. George A. O'Toole, Jr.

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the parties to this action and their counsel are subject to the following Protective Order:

         1. This protective order applies to all documents and to the information contained therein designated "CONFIDENTIAL" by the party producing same. This Order is intended to cover, without limitation, all records of the plaintiffs' taxes, business records, medical, and mental health records in this case.

         2. If a party seeks to establish that documents or information contained in the documents are not entitled to such status and protection, the party shall advise opposing counsel of the basis of the objection. If the parties cannot resolve the dispute within ten (10) days of such notification, the party seeking to establish confidentiality shall bring the matter to the Court for resolution and shall bear the burden of establishing that a protective order concerning the documents or information is appropriate. See Anderson v. Cryovac, 805 F.2d 1 (1st Cir. 1986).

         3. Confidential documents are to be used by the parties only in connection with litigating this case, unless the confidentiality of the documents is successfully challenged at a later date.

         4. Confidential material may only be disclosed as follows:

a. to the Court, in camera or under seal;
b. to attorneys of record, including their partners and associates, office support and any others who are directly assisting the attorneys of record, and such persons are to be informed of their obligations under this Order and will be bound by this Order; and
c. to experts, under these conditions: (1) the attorney of record shall first inform each expert that the disclosed material is confidential, is to be held in strict confidence, and is to be used solely to prepare and present evidence in the litigation, and that these restrictions are imposed by court order; and (2) the expert shall agree in writing to be bound by this Order.

         5. Confidential material may not be otherwise disclosed without the prior written consent of the party producing same, unless confidentiality is successfully challenged at a later date.

         6. Copies of confidential material may not be made except for an expert who requires a copy for review, file copies for counsel, and copies for use at depositions, in support of motions, and for use at trial. To the extent copies are made as provided in this paragraph, such copies shall themselves become confidential documents and shall be subject to all the terms of this Order as if they were a "first generation" document.

         7. Medical records and mental health treatment records may not be discussed with or provided to the defendants ...


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