Ordonez Velazquez v. United States

          STIPULATED PROTECTIVE ORDER

          Susan M. Bazis, United States Magistrate Judge

         This matter is before the Court on the parties' Joint Motion for Entry of Stipulated Protective Order. (Filing No. 17.) Upon a showing of good cause in support of the entry of a protective order to control the discovery and dissemination of confidential or proprietary information in this case (hereafter collectively referred to as “Confidential Information”), IT IS ORDERED THAT:

         1. Confidential Information will include confidential or proprietary business information. For purposes of this Order, the following categories of documents and information will generally be considered “Confidential Information” and subject to this Protective Order:

• Plaintiff, Elba Alicia Ordonez Velazquez's, medical or healthcare records or tax records;

• Confidential or proprietary business information.

         2. Confidential Information subject to this Protective Order may, depending on the content, be included in a variety of documents, including but not limited to: Agency records, documents produced pursuant to written discovery, answers to interrogatories, responses to requests for admission, deposition testimony, including all copies thereof, and other information disclosed in the context of discovery of this case by either party or disclosed pursuant to the discovery procedures created by the Federal Rules of Civil Procedure.

         3. Confidential Information shall not be disclosed or used for any purpose except the preparation and trial of this case, Elba Alicia Ordonez Velazquez, Luis Alberto Arriaga Guzman, Husband and Wife v. The United States of America, John or Jane Doe, M.D., Real Names Unknown, and will not be used in any other litigation.

         4. Confidential Information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:

a. attorneys actively working on this case;

b. any person who previously received or authored the materials;

c. persons regularly employed or associated with the attorneys actively working on the case;

d. Plaintiffs Elba Alicia Ordonez Velazquez and Luis Alberto Arriaga Guzman;

e. treating medical providers, expert witnesses, and consultants retained in connection with this proceeding;

f. mediators, facilitators, or other persons retained by the parties to assist in the resolution of this ...