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Mollett v. St. Joseph's Hospital Breese

United States District Court, S.D. Illinois

October 11, 2016

Holly Mollet, Plaintiff,
v.
St. Joseph's Hospital Breese, of the Hospital Sisters of The Third of St. Francis d/b/a HSHS St. Joseph's Hospital Breese and Hospital Sisters Health System, Defendants.

          Holly Mollet Ryan D. Rich (ARDC#6306824) Wham & Wham Lawyers Counsel for Plaintiff.

          St. Joseph's Hospital Breese, of the Hospital Sisters of The Third Order of St. Francis d/b/a HSHS St. Joseph's Hospital Breese and Hospital Sisters Health System Stephanie Dodge Gournis (ARDC#6215978) Kelly A. Petrocelli (ARDC #6278266) Drinker Biddle & Reath LLP Counsel for Defendants.

          STIPULATED PROTECTIVE ORDER

          DONALD G. WILKERSON United States Magistrate Judge.

         The parties having stipulated to the entry hereof, and the Court being otherwise fully advised in the premises;

         IT IS HEREBY ORDERED AS FOLLOWS:

         1. The following restrictions and procedures shall apply to certain information, documents and excerpts from documents supplied by the parties to each other in response to discovery requests:

         2. This Protective Order shall govern all materials deemed to be “Confidential Information.” Such Confidential Information shall include the following:

(a) Any documents referring or related to confidential and proprietary human resources or business information; financial records of the parties; contractual agreements; compensation of current or former personnel of Defendant(s); policies, procedures and/or training materials of Defendant(s); and/or the organizational structure of Defendant(s);
(b) Any documents from the personnel, medical or workers' compensation file of any current or former employee or contractor of Defendant(s);
(c) Any documents relating to the medical and/or health information of any of the current or former employees or contractors of Defendant(s);
(d) Any documents relating to the employee benefits received by current or former employees or contractors of Defendant(s);
(e) Any portions of depositions (audio or video) where Confidential Information is disclosed or used as exhibits.

         3. In the case of documents and the information contained therein, designation of Confidential Information produced shall be made by placing the following legend on the face of the document and each page so designated “CONFIDENTIAL” or otherwise expressly identified as confidential. Each Defendant will use its best efforts to limit the number of documents designated Confidential.

         4. Confidential Information shall be held in confidence by each qualified recipient to whom it is disclosed, shall be used only for purposes of this action, shall not be used for any business purpose, and shall not be disclosed to any person who is not a qualified recipient. All produced Confidential Information shall ...


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