Free Stipulation - District Court of Connecticut - Connecticut

` _ ase 3:03-cv-00443-MRK Document 34 Filed O4/O1/20*04 Page 1 of 4 l
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UNITED STATES DISTRICT COURT I
DISTRICT OF CONNECTICUT -
LORRAINE M. CAISSE, :
Plaintiff, CIVIL ACTION NO. l
: 303C\/0443(MRK) |
v. : I
DAY KIMBALL HOSPITAL,
: March 2, 2004
Defendant. :
STIPULATED PROTECTIVE ORDER g
It is hereby stipulated and agreed by and between the undersigned parties to '
this action that the following restrictions and procedures shall apply to defendant’s
response to certain of plaintiff s requests for production of documents. :
1. Defendant may mark certain documents “CONPIDENTIAL" if p
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either (a) the documents are contained in an employee’s "personnel tile" as that
term is defined in Connecticut General Statutes section 31-128 et seq. or (b) 1
defendant otherwise has a good faith basis for concluding that such documents N
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should be held confidential.
2. Unless otherwise ordered by the Court, the responses and documents
obtained will be held by the plaintiff solely for use in connection with the above-
captioned action.
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_ - ase 3:03-cv-OO443£;lVIFlj< Document 34 Filed O4/O1 Page 2 of 4
3. The data contained in the response shall not be disclosed to any Q
person except: h . _
(a) The individual plaintiff. l
(b) Counsel (and counsel’s staff) for the plaintiff. Q
(c) Counsel (and counsel’s staff) for the defendant.
(d) Any other person with the consent of counsel for plaintiff and
defendant.
4. Prior to plaintiff or plaintiffs counsel displaying the responses to any
person, or relaying the information contained in those responses to any person,
including any person described in the above categories, the plaintiff's counsel shall
apprise that person of the confidential nature of the data and apprise that person that
this court is enjoining the use of that data by her/him for any purpose other than this
litigation and has enjoined the disclosure of that data to any other person.
5. If the plaintiff, after review of the documents and information I
contained therein, believes such documents and/or information are necessary for
any motion, disclosure or other use in connection with this litigation that would
subject the documents or the information in those documents to be put into the
public domain, as would be the case with a filing in connection with a motion in l
court or use at trial, plaintiffs counsel shall contact defendant’s counsel to discuss i
such disclosure, and shall give defendant’s counsel a reasonable opportunity to
move that such material be filed under seal with the Court. Should such a motion
be made, plaintiffs counsel agrees that, while such motion is pending, he shall not
tile such material with the Court.
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4 _ · ase 3:O3—cv-OO443TlV|Fil§ Document 34 Filed O4/O1 Page 3 of 4
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4 6. The parties agree that should either of them believe that matters Y
4 discussed in a deposition are confidential, either party may, at the deposition or 4
4 within ten (10) days following the receipt of the transcript of the deposition, 4
designate portions of the deposition testimony as “CONFIDENTIAL". Such
4 testimony shall be treated as other confidential material under this Stipulated 4
Protective Order.
7. The foregoing is entirely without prejudice to the right of any party
to apply to the court for any further protective order relating to confidential
documents or information; or to object to the production of documents; or to apply
to the court for an order compelling production of documents; or for modification
of this order.
8. The parties agree that upon execution of this Stipulated Protective
Order it shall be binding on the parties as a contract.
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· ase 3:03-cv-OO443;MF1l§ Document 34 Filed O4/O1_/20Q;l Page 4 of 4 l
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THE PLAINTIFF i
LORRA11~}12 CAIS E I y
BY1 6* !
r teau — ct09771 L
Madsen, Prestley & Parenteau `
_ 111 Huntington Street
A P.O. B6x 1631 1
New London, CT 06320
I Tel. N0. 860-442-2466
Fax N0. 860-447-9206 `
lr []3f€HIC8U@Hl[].|
Her attorney
THE DEFENDANT Q
DAY KIMBALL HOSPITAL E
By {
Hugh F. Murray, — ctl 1418
Scott E. Schaffer — ct25325
Murtha Cullina LLP
CityPlace I — 185 Asylum Street
Hartford, CT 06103-3469 *
Tel, N6. (860) 240-6000 l
Fax N6. (860) 240-6150 y
hmurra @Il1UI`{I2l12lW’.()()1I} l
§v§Ch3ffCl`@mUT[hg§LV;$I_$]1H =
Its Attorneys
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