United States District Court, S.D. Illinois
Mollet Ryan D. Rich (ARDC#6306824) Wham & Wham Lawyers
Counsel for Plaintiff.
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
STIPULATED PROTECTIVE ORDER
G. WILKERSON United States Magistrate Judge.
parties having stipulated to the entry hereof, and the Court
being otherwise fully advised in the premises;
HEREBY ORDERED AS FOLLOWS:
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
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
(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
(e) Any portions of depositions (audio or video) where
Confidential Information is disclosed or used as exhibits.
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.
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 ...