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Williams v. RHA Health Services, LLC

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

August 6, 2019


          JACKSON LEWIS P.C., PAUL S. HOLSCHER N. C. State Bar No. 33991 SIDNEY O. MINTER Attorneys for Defendant.

          Julie H. Fosbinder N.C. State Bar No. 19400, Attorney for Plaintiff.


          David C. Keesler United States Magistrate Judge

         The Parties have jointly moved the Court pursuant to Local Rule 7.1, Rule 26(c) of the Federal Rules of Civil Procedure and the Pretrial Order and Case Management Order (DE # 21), for entry of a Consent Protective Order to expedite the flow of discovery materials; facilitate the prompt resolution of discovery disputes, as well as disputes concerning confidentiality; protect certain materials designated as confidential (“Confidential Materials”); and ensure that protection is afforded only to materials so designated.


         1. General Scope of the Agreement. This Consent Protective Order shall govern certain documents and other materials produced in response to any discovery request or other request for information by Plaintiff Rebecca Williams (“Plaintiff”) and Defendant RHA Health Services, LLC (“Defendant”), in this action, specifically including, but not limited to, answers to requests for admissions; answers to interrogatories; responses to requests for production of documents and documents produced in accordance therewith; documents subpoenaed in connection with depositions; deposition testimony; and any deposition transcript or portion thereof as to which protection is sought in accordance with this Agreement. The following documents and/or information may be designated as “Confidential Materials” pursuant to this Order: (a) Plaintiff's personal financial data, medical records, and other documents including health-related information, including tax returns of Plaintiff; (b) personal information of Defendant's employees or former employees, including, but not limited to: social security numbers, tax information, and health insurance/ health-related information; and (c) personal or personnel file information and records of Defendant's current and/or former employees.

         2. Redaction of Certain Information. The Parties shall be allowed to redact the following information from any documents provided pursuant to this Order: (a) social security numbers, (b) dates of birth and (c) financial account numbers; (d) insurance policy numbers; and (e) driver's license numbers.

         3. Designation as Confidential: Good Faith Requirement. Any party producing or furnishing information of any nature to another party, to the Court, or at a deposition in connection with this litigation may designate documents or information as “Confidential Materials, ” in accordance with the procedures set forth herein. Such information could include a document or part thereof, interrogatory answer, response to request for admissions, deposition testimony, excerpts and summaries of such information, or other materials as set forth in Paragraph 1 of this Agreement. Such designation shall be made at the time the information is produced or furnished, or at a later time as provided herein.

         No party may designate information as “Confidential Materials” without first determining in good faith that the information may be so designated as provided in this Order and as contemplated by Rule 26(c) of the Federal Rules of Civil Procedure. In the event there is a dispute between the parties regarding what is considered “Confidential Materials, ” the Court shall be the ultimate decision maker.

         4. Procedure for Designating Information as Confidential. Parties may designate “Confidential Materials” in the following manner:

a) In the case of documents or other written materials, by affixing to each page of every such document, at the time of production, the word “Confidential” by stamp or other method which will make the word conspicuous;
b) In the case of answers to interrogatories, designation shall be made by placing the word “Confidential” adjacent to or at the end of any answer deemed to contain confidential information. Alternatively, answers deemed to contain confidential information may be bound separately and marked with the word “Confidential;” and
c) In the case of depositions or other pretrial testimony in this action by parties or any of their officers or employees, by a statement to that effect on the record by counsel for the party who claims that Confidential Materials are about to be or have been disclosed. Alternatively, a party may designate information disclosed at such deposition as Confidential Materials by informing all parties in writing, within thirty (30) days of receipt of the transcript or other date as agreed upon by the parties, of the specific pages and lines of the deposition transcript which are deemed Confidential. Each party shall attach a copy of such written statement to the face of the transcript and each copy thereof in its possession, custody, or control. All depositions shall be treated as Confidential for a period of thirty (30) days after a full and complete transcript of the deposition is available or other date as agreed upon by the parties. Unless the parties intend to designate all of the information contained within a particular document or deposition testimony as Confidential Materials, counsel for that party should indicate in a clear fashion the portion of the document or testimony which is intended to be designated as confidential.

         5. Restricted Use of Confidential Information. The use of information designated as “Confidential Materials” will be ...

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