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Henderson v. Physician Affiliate Group of New York P.C.

United States District Court, S.D. New York

January 7, 2020

CASSANDRA HENDERSON, MD, Plaintiff,
v.
PHYSICIAN AFFILIATE GROUP OF NEW YORK P.C., NEW YORK CITY HEALTH AND HOSPITALS CORPORATION, CARMEN SULTANA, MD, and JOHN DOE 1-10, Defendants.

          WALDEN MACHT & HARAN LLP Milton L. Williams Adam Cohen Attorneys for Plaintiff

          GEORGIA M. PESTANA Acting Corporation Counsel of the City of New York Attorney for Defendants

          Kerrin A. Bowers Assistant Corporation Counsel

          STIPULATION AND PROTECTIVE ORDER

          Jesse M. Furman U.S.D.J.

         WHEREAS, the Parties have sought or will seek certain documents and information from each other in discovery in this action, which the Parties deem to be confidential ("Confidential Information"); and

         WHEREAS, the Parties would object to the production of those documents and information unless there is appropriate protection for their confidentiality, as described in the Protective Order below; and

         WHEREAS, in accordance with Federal Rule of Civil Procedure Rule 26(c), the Court issues this Protective Order, upon the joint request of the Parties, for the purposes of facilitating the disclosure of information and assuring the confidentiality of information that may be disclosed by the Parties during discovery in this action;

         IT IS THEREFORE ORDERED THAT:

         1. As used herein, "Confidential Materials" shall mean all documents that a party in good faith designates as "Confidential Materials."

2. When used in this Stipulation and Order, "Disclosing Party" shall refer to the party producing materials designated as Confidential Material.

         3. When used in this Stipulation and Order, "Receiving Party" shall refer to the party receiving materials designated as Confidential Material.

         4. Confidential Materials shall not include: (a) documents and information that is publicly available; (b) documents and information in the possession of the Receiving Party at the time of disclosure by the Disclosing Party not previously acquired from the Disclosing Party; (c) documents and information acquired by the Receiving Party from a non-party to this action not under any obligation of confidentiality to the Disclosing Party or not in violation of the Disclosing Party's rights; and (d) documents and information independently developed by the Receiving Party without any use of any Confidential Materials.

         5. Method of Designating Documents and Information as Confidential Materials. There are three methods by which a Party may designate materials to be Confidential: (a) by marking "Confidential" on each page of the document or otherwise marking the Confidential Materials "Confidential" in a fairly conspicuous fashion prior to production of such document; or (b) by designating in writing the Bates-stamp numbered pages to be designated as "Confidential" prior to production of such documents deemed to be Confidential; or (c) a Party may designate deposition exhibits or portions of deposition transcripts as Confidential Material either by: (i) indicating on the record during the deposition that a question calls for Confidential information, in which case the reporter will bind the transcript of the designated testimony in a separate volume and mark it as "Confidential Information Governed by Protective Order;" or (ii) notifying the reporter and all counsel of record, in writing, within thirty (30) days after a deposition has concluded, of the specific pages and lines of the transcript that are to be designated "Confidential," in which case all counsel receiving the transcript will be responsible for marking the copies of the designated transcript in their possession or under their control as directed by the Disclosing Party or that person's counsel. During the 30-day period following a deposition, all Parties will treat the entire deposition transcript as if it had been designated Confidential.

         6. Subsequent Designation of Confidential Materials. Documents and/or materials produced in this action that are not identified as Confidential Materials when they were initially produced may thereafter (including within a reasonable time after entry of this Order), be designated as Confidential by the Party by providing written notice to counsel and any other person who received such documents or materials. Each Party or person who receives such written notice shall endeavor to retrieve any Confidential Information that may have been disseminated, shall affix a "Confidential" designation to it, and shall ...


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