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Preeson v. Parkview Medical Center, Inc.

United States District Court, D. Colorado

January 22, 2016

Kimberly Preeson, Plaintiff,
v.
Parkview Medical Center, Inc., Laura Harrison, individually, and as Director of Admissions and Financial Counseling of Parkview Medical Center, Inc., Defendants.

JOINT PROPOSED PROTECTIVE ORDER

KATHLEEN M. TAFOYA UNITED STATES MAGISTRATE JUDGE.

Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which may improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:

1. This Protective Order shall apply to all documents, materials and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, deposition exhibits and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.
2. As used in this Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. A party may designate as “CONFIDENTIAL” any document or portion of a document that is confidential and implicates common law and statutory privacy interests of the parties, either of them, their employees or representatives, or their other policyholders or other customers. 45 C.F.R. § 164.508 (prohibiting disclosure of medical information of patients); C.R.S. § 25-1-1202 (providing an index to all Colorado laws regarding medical record confidentiality); 15 U.S.C. § 6801 et seq. (providing that financial institutions have an affirmative and continuing obligation to respect the privacy of their customers and to protect the security and confidentiality of those customers’ nonpublic personal information); Corbetta v. Albertson’s, Inc., 975 P.2d 718, 720-21 (Colo. 1999) (recognizing the confidentiality of employee information); Fed.R.Civ.P. 26(c)(1)(G) (recognizing that trade secrets and commercial information may be subject to protective order).
4. Confidential information shall not be disclosed or used for any purpose except the preparation and trial of this case. No person receiving such CONFIDENTIAL information shall, without the consent of the party producing it or further Order of the Court, directly or indirectly, transfer, disclose, or communicate in any way the contents of the CONFIDENTIAL information to any person other than those specified in Paragraph 5. Each party shall use appropriate safeguards to protect CONFIDENTIAL information of other parties or third-parties from being disclosed in a manner that would be inconsistent with this Protective Order.
5. Access to any CONFIDENTIAL information shall be limited to:
a. Attorneys actively working on this case;
b. The parties to this action;
c. Persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by those attorneys for work on this case;
d. The agents or employees of the parties, who are needed for discovery, preparation, trial or other proceedings or work in this case;
e. Expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
f. Court Personnel, but see Sec. 11 regarding public filing of CONFIDENTIAL information;
g. Stenographic reporters who are engaged in proceedings necessarily incident to the ...

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