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Perez v. Gordinez

United States District Court, Seventh Circuit

June 25, 2013

FRANCISCO PEREZ, ID#B-78905, Plaintiff,
v.
S.A. GORDINEZ, DIRECTOR OF I.D.O.C. PAUL TALBOT, MEDICAL DIRECTOR OF DANVILLE C.C. DR. LOIS SCHICKER, MEDICAL DIRECTOR OF THE STATE OF ILLINOIS, DR. ARTHUR FUNK FOR WEXFORD, INC., AND THE P.A. FEMALE WHICH COMES TO DANVILLE ON THE WEEKEND, MARCIA KEYS, DIETARY MANAGER FOR DANVILLEC.C., Defendants.

PROTECTIVE ORDER

MICHAEL P. McCUSKEY, District Judge.

THIS CAUSE comes before the Court, IT IS THEREFORE ORDERED:

I. Categories of Material and/or Information

It is anticipated that certain information covered by or contained in documents produced in this action may contain or constitute confidential information that warrants protection from disclosure. Each party or entity, disclosing information, which it reasonably believes in good faith to constitute confidential materials, may, at the time of production, designate such information as "Confidential." Such "Confidential" information shall specifically include, but not be limited to, policies, procedures, and clinical protocols.

A. If a party believes that any written, recorded, or graphic material, tangible items or any other form of information that it produces in this action pursuant to pretrial discovery, court order, or agreement of the parties contains "Confidential" information, it may designate such material as "Confidential" either by stamping the word "Confidential" on the document or by other means that notifies the other parties that the information is subject to this Protective Order. Such designation must occur prior to transmission of a physical copy thereof to counsel for any other party to this action. Materials designated as "Confidential" and all writings, including court papers, that quote from, summarize or comment upon any such material shall be treated as confidential as set forth in this Protective Order.

B. No "Confidential" information may be disclosed to any person except the following:

i. the parties' legal counsel of record and their associates, paralegals, or other staff who are assisting in the representation;
ii. persons retained as experts or consultants by the recipient party;
iii any person who was the author or recipient of a "Confidential" document or a copy of such a document, or who was referred to in such document;
iv. the Court, including court reporters, stenographic reporters, and other court personnel;
v. individuals testifying about the same during depositions or at trial;
vi. the parties themselves, so long as such disclosure takes place only in the office of the parties' legal counsel of record and so long as the parties are not permitted to retain copies or originals of such documents; and
vii. any other person to whom the producing party or respondent-in-discovery agrees in writing.

Individuals or entities permitted access to any of the "Confidential" information pursuant to Paragraph B hereof shall not show, convey, or reproduce any document so designated, or parts thereof, or copies thereof, to any individual or any entity who would not otherwise have ...


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