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Maxwell v. St. Francis Health Center

United States District Court, D. Kansas

December 7, 2017

STEPHANIE J. MAXWELL, Plaintiff,
v.
ST. FRANCIS HEALTH CENTER, et al., Defendants.

          Bryce B. Bell Counsel for Plaintiff Stephanie Maxwell

          Jeffrey A. Kennard Counsel for Defendant St. Francis Health Center

          Louis J. Wade Counsel for Defendant H. Kent Hollins PA

          Seth A. Lowry Counsel for Defendant City of Topeka

          Louis J. Wade Counsel for Defendant H. Kent Hollins

          STIPULATED PROTECTIVE ORDER

          K. GARY SEBELIUS U.S. MAGISTRATE JUDGE

         For good cause shown under Fed.R.Civ.P. 26(c), the Court grants the parties' joint request and hereby enters the following Protective Order:

         1. Scope.

         All documents and materials produced in the course of discovery of this case, including initial disclosures, responses to discovery requests, all deposition testimony and exhibits, and information derived directly therefrom (hereinafter collectively “documents”), are subject to this Order concerning Confidential Information as set forth below. As there is a presumption in favor of open and public judicial proceedings in the federal courts, this Order will be strictly construed in favor of public disclosure and open proceedings wherever possible.

         2. Definition of Confidential Information.

         As used in this Order, “Confidential Information” is defined as information that the producing party designates in good faith has been previously maintained in a confidential manner and should be protected from disclosure and use outside the litigation because its disclosure and use is restricted by statute or could potentially cause harm to the interests of disclosing party or nonparties. For purposes of this Order, the parties will limit their designation of “Confidential Information” to the following categories of information or documents:

(a) Documents produced by Plaintiff or Defendants containing the nonpublic personal information of consumers;
(b) Documents produced by Plaintiff or Defendants containing customer information or personal information of third parties and/or the parties' employees; and
(c) Documents produced by Plaintiff or Defendants reflecting trade secrets, proprietary information or software, or Plaintiff s or Defendants' confidential financial matters.
Information or documents that are available to the public may not be designated as Confidential Information.

         3.Form and Timing of Designation.

         The producing party may designate documents as containing Confidential Information and therefore subject to protection under this Order by marking or placing the words “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” (hereinafter “the marking”) on the document and on all copies in a manner that will not interfere with the legibility of the document. As used in this Order, “copies” includes electronic images, duplicates, extracts, summaries or descriptions that contain the Confidential Information. The marking will be applied prior to or at the time the documents are produced or disclosed. Applying the marking to a document does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order. Copies that are made of any designated documents must also bear the marking, except that indices, electronic databases, or lists of documents that do not contain substantial portions or images of the text of marked documents and do not otherwise disclose the substance of the Confidential Information are not required to be marked. By marking a designated document as confidential, the designating attorney or party appearing pro se thereby certifies that the document contains Confidential Information as defined in this Order.

         4. Inadvertent Failure to Designate.

         Inadvertent failure to designate any document or material as containing Confidential Information will not constitute a waiver of an otherwise valid claim of confidentiality pursuant to this Order, so long as a claim of confidentiality is asserted within twenty calendar days after discovery of the inadvertent failure to designate.

         5. Depositions.

         Deposition testimony will be deemed confidential only if designated as such. The Parties shall have 21 days from the date a deposition is taken, or 14 days from the date a deposition transcript is received, whichever date is later, to serve a notice to all parties designating portions of a deposition as Confidential Information. Such designation must be specific as to the portions of the transcript and/or any exhibits to be protected.

         6. Protection of ...


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