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Stailey v. Gila Regional Medical Center

United States District Court, D. New Mexico

December 23, 2016

MARIE STAILEY, Plaintiff,
v.
GILA REGIONAL MEDICAL CENTER, et al., Defendants.

          THOMAS L. JOHNSON Attorney for Plaintiff.

          CHRISTOPHER M. MOODY Attorney for Defendant.

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

          THE HONORABLE GREGORY J. FOURATT UNITED STATES MAGISTRATE JUDGE

         1. PURPOSES AND LIMITATIONS

         Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this arbitration may be warranted. Accordingly, the parties hereby stipulate to the entry of the following Stipulated Confidentiality and Protective Order.

         2. DEFINITIONS

         2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that a Party reasonably believes qualify for protection under Federal Rule of Civil Procedure 26(c).

         2.3 “CONFIDENTIAL-ATTORNEYS' EYES ONLY” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that a Party (1) reasonably believes qualify for protection under Federal Rule of Civil Procedure 26(c) and (2) considers in good faith to contain highly sensitive confidential information or proprietary business information.

         2.4 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff).

         2.5 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS' EYES ONLY.” 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

         2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.

         2.8 House Counsel: attorneys who are employees of a party to this action. House Counsel does not include Outside Counsel of Record or any other outside counsel.

         2.9 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         2.10 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.

         2.11 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs).

         2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.

         2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

         2.14 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL” or “CONFIDENTIAL-ATTORNEYS' EYES ONLY.” 2.15 Receiving Party: a Party that ...


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