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United States ex rel. Winter v. Gardens Regional Hospital and Medical Center, Inc.
United States District Court, C.D. California
October 27, 2017
UNITED STATES OF AMERICA ex rel. JANE WINTER, Plaintiff,
GARDENS REGIONAL HOSPITAL AND MEDICAL CENTER, INC. D/B/A TRI-CITY REGIONAL MEDICAL CENTER, a California Corporation; ROLLINSNELSON LTC CORP., a California Corporation; S&W HEALTH MANAGEMENT SERVICES, INC., a California Corporation; VICKI ROLLINS, an individual; BILL NELSON, an individual; BERYL WEINER, an individual; PRODE PASCUAL, M.D., an individual; RAFAELITO VICTORIA, M.D., an individual; ARNOLD LING, M.D., an individual; CYNTHIA MILLER-DOBALIAN, M.D., an individual; EDGARDO BINOYA, M.D., an individual; NAMIKO NERIO, M.D., an individual; MANUEL SACAPANO, M.D., an individual, Defendants.
LAW FIRM, APC MICHAEL J. KHOURI ANDREW B. GOODMAN Attorneys
for qui tarn plaintiff, JANE WINTER.
OFFICES OF MICHAEL D. GONZALEZ MICHAEL D. GONZALEZ ANDREA D.
VAZQUEZ Attorneys for defendant, PRODE PASCUAL, M.D.
SPERTUS, LANDES & UMHOFER, LLP MATTHEW DONALD UMHOFER
ELIZABETH J. LEE Attorneys for defendants, ROLLINSNELSON LTC
CORP., VICKI ROLLINS, and BILL NELSON.
DUNN & CRUTCHER, LLP THAD A. DAVIS JAMES L. ZELENAY, JR.
VIVEK GOP ALAN Attorneys for defendants, BERYL WEINER and
S&W HEALTH MANAGEMENT SERVICES, INC.
[PROPOSED] PROTECTIVE ORDER
GOVERNING THE DISCLOSURE OF HEALTH INFORMATION AND
CONFIDENTIAL INFORMATION [STIPULATION SUBMITTED
showing of good cause in support of the entry of a Protective
Order to protect the discovery and dissemination of
confidential information, including Protected Health
Information and proprietary business information, IT IS
Protective Order shall apply to all documents, materials, and
information, including without limitation, documents
produced, answers to interrogatories, responses to requests
for admission, deposition testimony, and other information
disclosed pursuant to the disclosure or discovery duties
created by the Federal Rules of Civil Procedure
used in this Protective Order:
(a) "Document" is defined as provided in FRCP
34(a), including any electronically-stored information, or
tangible thing. A draft or non-identical copy is a separate
document within the meaning of this term.
(b) "Protected Health Information" or
"PHI" means "protected health
information" as defined in 45 C.F.R. § 160.103, and
also includes individually identifiable information that may
be subject to the provisions of the Privacy Act, 5 U.S.C.
§ 552a, or the provisions of 42 U.S.C. § 1306.
"Protected Health Information" shall include, but
is not limited to, medical records, claim data, claim forms,
grievances, appeals, or other documents or records that
contain any patient health information required to be kept
confidential under any state or federal law, including 45
C.F.R. Parts 160 and 164 promulgated pursuant to the Health
Insurance Portability and Accountability Act of 1996
(see 45 C.F.R. §§ 164.501 & 160.103),
and the following subscriber, patient, or member identifiers:
(2) all geographic subdivisions smaller than a State,
including street address, city, county, precinct, and zip
(3) all elements of dates (except year) for dates directly
related to an individual, including birth date, admission
date, discharge date, age, and date of death;
(4) telephone numbers;
(5) fax numbers;
(6) electronic mail addresses;
(7) social security numbers;
(8) medical record numbers;
(9) health plan beneficiary numbers;
(10) account numbers;
(11) certificate/license numbers;
(12) vehicle identifiers and serial numbers, including