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Varney v. Novant Health, Inc.

United States District Court, W.D. North Carolina, Charlotte Division

May 21, 2019

APRIL VARNEY, Plaintiff,
v.
NOVANT HEALTH, INC., Defendant.

          Mathew E. Flatow N.C. State Bar No. 35282 Arcangela M. Mazzariello N.C. State Bar No. 23846 David A. Swenton N.C. State Bar No. 52537 SeiferFlatow, PLLC Attorneys for Plaintiff

          Patrick E. Kelly, N.C. State Bar No. 16703 Kimberly J. Kirk, N.C. State Bar No. 44255 David E. Stevens, pro hac vice Johnston, Allison & Hord, P.A. 1065 East Morehead Street Charlotte, North Carolina 28204 Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

          Graham C. Mullen, Judge.

         In order to preserve and maintain the confidentiality of certain information served, produced, or otherwise disclosed or communicated by, between, or among the parties to this action, the Court, all parties to this action and/or third persons or entities hereby stipulate and agree, and IT IS ORDERED THAT:

         1. Information or documents served, produced, or otherwise disclosed or communicated by any person or entity in connection with this action (“Materials”) that constitutes or contains confidential or proprietary information including, without limitation, information or documents that fall within one or more of the following categories shall be referreed to as “Protected Documents”:

(a) materials related to the confidential medical records of April Varney or any other person protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and any information derived from such information or documents, including, without limitation, written discovery responses, extracts, memoranda, notes, records or transcripts of deposition testimony, and correspondence quoting from or summarizing such information;
(b) information that reveals trade secrets;
(c) research, technical, commercial or financial information that the party has maintained as confidential;
(d) personal identity information, including social security numbers;
(e) income tax returns, including W-2 forms; or
(f) personnel or other employment records of a person who is not a party to the case.

         When used in this Protective Order, the word “documents” is used in its broadest sense and meals all written and computerized materials, videotapes, and all other tangible items and items in magnetic or electronic form. Protected Documents designated by any party or third party as either or both “Confidential-Subject to Protective Order” or “Attorney Eyes Only, ” and served, produced, or otherwise communicated in this action shall be Protected Documents and given confidential treatment as described below.

         2. Materials produced or otherwise disclosed or communicated in this action that a person or entity deems to constitute a Protected Document may be designated as such as follows: (1) by the person or entity producing, disclosing, or communicating the materials marking the document or thing with a legend stating “Confidential-Subject to Protective Order” or “For Attorney Eyes Only, ” or by either or both of such written designation(s) using Bates number type specifications or other conspicuous designation; or (2) by any party receiving them making such written or, if during a proceeding with a court reporter present, on-the-record designation. Any written discovery response marked with the legend “Confidential-Subject to Protective Order” or “For Attorney Eyes Only” must be bound separately from any response(s) not constituting a Protected Document.

         3. Protected Documents shall be treated as confidential and used solely for the purpose of prosecuting or defending against any claim asserted in this action. Except upon the prior written consent of the producing person or entity, or upon further order of the Court, any Protected Documents designated “For Attorney Eyes Only” may ...


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