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Herminia Lopez, As An Individual, and L.L., By and Through His General Guardian Jose Lopez v. Melva Dockings

November 20, 2012

HERMINIA LOPEZ, AS AN INDIVIDUAL, AND L.L., BY AND THROUGH HIS GENERAL GUARDIAN JOSE LOPEZ, PLAINTIFFS,
v.
MELVA DOCKINGS, AS AN INDIVIDUAL AND AS TRUSTEE OF DOCKINGS FAMILY TRUST, DEFENDANTS.



The opinion of the court was delivered by: The Honorable Ralph Zarefsky United States Magistrate Judge

Assigned to Courtroom: 10 The Hon. George H. Wu

[PROPOSED] PROTECTIVE ORDER

Action Commenced: August 24, 2012 Trial Date: Not Set Discovery Cut-Off: Not Set Law & Motion Cut-Off: Not Set

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT -1-[PROPOSED] PROTECTIVE ORDER

The Parties have entered into a Stipulation for the entry of a Protective Order to govern the disclosures, dissemination, and use of "Confidential Information" produced by the Parties in this action. The Court having reviewed the Stipulation and finding good cause for the entry of such an order, hereby orders that the following Protective Order ("the Order") shall apply to any information designated as "Confidential" pursuant to the agreement of the Parties or Order of the Court.

1. Confidential Information

Plaintiffs contend that Plaintiffs' medical records and medical information are confidential, private, sensitive information. Defendant intends to obtain Plaintiffs' medical records and medical information through discovery in this action. This stipulation and Order is intended to preserve the confidentiality of those medical records, the information obtained therein, and any other medical information about Plaintiffs disclosed by Plaintiffs in discovery. Therefore, Plaintiffs seek to keep medical records and documents related to their medical information confidential.

Any documents produced in discovery that contain or reveal medical records or medical information, or that are designated as Confidential Information under the terms of the Order, and all copies, recordings, abstracts, excerpts, analyses, court filings, or other writings that contain, reflect, reveal, suggest or otherwise disclose such Confidential Information shall be deemed to be Confidential Information.

2. Parties

A "Disclosing Party" is the party who produces or discloses Confidential Information, or on whose behalf such information is disclosed, to a receiving party's attorneys. A "Receiving Party" is any party (either Plaintiff or Defendant) that receives or is permitted to receive Confidential Information from the Disclosing Party under the Order.

3. Identification

a. Confidential Information may be designated by a Disclosing Party as "Confidential" by marking it as "Confidential" or by designating the information as "Confidential" by any separate writing sufficient to identify the information which is provided to the Receiving Party.

b. Where such designation is made by stamping or similar means, it shall be made by placing notice on the document, thing, response to discovery, deposition or court transcript or record, information, or document stored on diskette or otherwise in computer usable form, or tangible thing or object, in such a manner as will not interfere with the legibility or accessibility of the Confidential Information.

c. Information and documents designated as "Confidential Information" shall be subject to the disclosure restrictions of the Order. Any Receiving Party or other person who receives a document so designated is subject to this Protective Order and the jurisdiction ...


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