Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Scott v. Sree-Lumberton, LLC

United States District Court, E.D. North Carolina, Southern Division

March 20, 2018

BARBARA SCOTT, et al., Plaintiffs,
v.
SREE-LUMBERTON, LLC, et al., Defendants.

          Jack Holtzman, Emily Turner NORTH CAROLINA JUSTICE CENTER Counsel for Plaintiffs

          ADDENDUM TO CONSENT PROTECTIVE ORDER: CONFIDENTIAL HEALTH INFORMATION (AS MODIFIED)

          JAMES E. GATES, UNITED STATES MAGISTRATE JUDGE.

         1. This Addendum to the Consent Protective Order (Dkt. 64) shall govern the use and disclosure of all material and information designated as "CONFIDENTIAL - MEDICAL" pursuant to Paragraph 3 of this Addendum. The terms of the Consent Protective Order shall apply to material and information so designated, except as altered by this Addendum.

         2. "Confidential Health Information" means any document or information supplied in any form, or any portion thereof, that identifies an individual in any manner and relates to the past, present, or future care or health services regarding the individual, relates to the physical or mental health condition of such individual in any way, or relates to the provision of health care to such individual. "Confidential Health Information" includes, but is not limited to, medical bills, claims forms, charge sheets, medical records, medical charts, test results, notes, dictation, summary forms, intake forms, and related records. "Confidential Health Information" also includes all notes, summaries, compilations, extracts, abstracts, or oral communications that contain, are based on, or are derived from "Confidential Health Information."

         3. Either party may designate any documents or other materials as "CONFIDENTIAL - MEDICAL" if counsel believes, in good faith, that the documents contain or reflect Confidential Health Information.

         4. Any Confidential Health Information filed with the Court shall be filed under seal according to the procedures set forth in the Consent Protective Order.

         5. Materials designated as "CONFIDENTIAL - MEDICAL" shall be used or disclosed by the receiving party solely for purposes of prosecuting or defending this action, and shall not be revealed, discussed, or disclosed to any person or entity other than:

(a) The attorneys that have entered appearances in this litigation and necessary staff employed by such attorneys;
(b) The Court in this action, or any other court having jurisdiction over discovery procedures in the action, any court reporter or typist recording or transcribing testimony in this action, and any outside, independent reproduction firm;
(d) Medical or psychiatric experts retained by the Parties in connection with this matter, whether testifying or non-testifying;
(e) Witnesses during their depositions whose testimony concerns either the subject matter of the documents containing Confidential Health Information or Plaintiffs' allegations of emotional distress;
(f) Individuals who authored or previously received the document in question; or
(g) Other persons who may be designated by consent of all attorneys of record or pursuant to Court order.

         6. Prior to disclosure to any person pursuant to Paragraphs 5(d), (e), or (g), such person shall be furnished with a copy of Consent Protective Order and this Addendum and shall be required to certify in writing that he or she has read this Order and Addendum, understands them, and agrees to be bound by their terms. Such certification shall be in the form of the Acknowledgment of Stipulation and Protective Order included as Attachment ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.