Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Parker v. United States

United States District Court, D. Nebraska

April 30, 2019

SAMONE T. PARKER, Individually, and as Special Administrator of the ESTATE of TONYA L. DRAPEAU, Deceased, Plaintiff,
v.
THE UNITED STATES OF AMERICA, VISTA STAFFING SOLUTIONS, INC., NEVINE MAHMOUD, M.D., and ROBIN HARRIS, R.N., Defendants.

          STIPULATED PROTECTIVE ORDER

          Michael D. Nelson United States Magistrate Judge

         This matter is before the Court on the Parties' Joint Motion for Entry of Stipulated Protective Order (Filing 124). 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:

         The Parties' Joint Motion for Entry of Stipulated Protective Order (Filing 124) is granted.

         IT IS FURTHER ORDERED:

         1. 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's employment, medical or healthcare records;

         • Plaintiff's tax records;

         • Confidential, trade secret, or proprietary business information;

         • Employment-related records of the Winnebago Hospital, including current and former employees or contractors;

         • Any other information protected by the HIPAA Standards for Privacy of Individually Identifiable Health Information, 45 C.F.R. Parts 160 and 164 and/or the Privacy Act, 5 U.S.C. § 552a.

         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. Defendants may redact dates of birth, home addresses, and Social Security Numbers from Confidential Information. With respect to employment-related files related to current or former employees or contractors of the United States, absent further order from the Court, Defendants are not required to provide copies of any medical records -- excluding alcohol or drug testing -- of the individuals that are contained in the file. With respect to employment-related files, Defendants are not required to provide documents related to benefits for Dena Neiman, but shall provide any benefit information in the candidate files of Dr. Mahmoud, Robin Harris and Brandon Smith, if available. The parties further agree, with respect to any criminal history requests requests, the United States will only produce information in the employment-related files at Winnebago Hospital that shows the employee or contractor has been convicted of a felony, of making a false statement, or of any other crime involving fraud or dishonesty.

         4. Confidential Information shall be used by Plaintiff and her representative(s) only for the purpose of litigating this case, Samone T. Parker v. United States of America, et al., No. 8:18-CV-123, including any appeals, and shall not be disclosed by the Plaintiff or her representative(s) to the public or any other person or entity for any reason other than for purposes of litigating this case, including any appeals.

         5. Confidential Information shall not, without the consent of the party producing it or further Order of the Court, be disclosed ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.