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Sidanov v. Magellan Healthcare, Inc.

United States District Court, S.D. New York

January 14, 2020


          SHALOM LAW, PLLC Jonathan Shalom, Esq. POLAT LAW GROUP, PLLC Emre Polat, Esq. Attorneys for Plaintiff

          KELLEY DRYE & WARREN LLP Barbara E. Hoey, Esq. Alyssa M. Smilowitz, Esq. Attorneys for Defendants


         Plaintiff Galina Sidanov (“Plaintiff”) and Defendants Magellan Healthcare, Inc.[1](“Magellan”) and JoAnn Harris (collectively “Defendants”), each a “Party” or collectively, “the Parties, ” hereby agree to the following Stipulation and Order of Confidentiality (“Order”) regarding certain documents and information that will be produced by the Parties during discovery in the above-captioned action (the “Action”).

         1. The Parties acknowledge that discovery in this Action may require the disclosure of documents and other materials that are commercially sensitive, contain personal medical information, and/or are otherwise confidential in nature.

         2. The Parties hereby agree that “Confidential Information” shall include information, documents, data, portions of discovery materials, if any, including but not limited to deposition transcripts, interrogatory answers, and responses to requests for admissions, if the information contained therein has not been made publicly available and is the kind of information the Parties believe in good faith to be trade secret, proprietary, business confidential, competitively sensitive information or Personal Information. “Personal Information” means Confidential Information that includes internal business materials and materials related to Defendants' (or their associated entities') business process, and individually identifiable personal information about the Defendants' (or their associated entities') clients, patients, employees, and former employees (including Plaintiff), and includes but is not limited to social security numbers, personnel files, date of birth, financial information, medical and health information, and performance ratings, performance information, workers' compensation information, information relating to a spouse, partner or dependent, discipline documentation, promotion information, compensation information, monetary transaction information, employment benefit information, retirement information and termination information.

         3. Any Party subject to discovery in this Action may designate documents; deposition testimony, transcripts, and exhibits; responses to interrogatories; responses to requests for admission; and other written, recorded, or graphic information and materials produced by a Party or non-party in the course of this litigation as “Confidential Information.” In the case of documents and other materials produced by a Party, the “Confidential” designation shall be made if review by the producing Party or an attorney for the producing Party permits a good faith and reasonable basis for believing that the Confidential Information is of a sensitive nature.

         4. The producing Party shall designate information as Confidential Information by stamping the word “Confidential” on each page of the document, in the case of documents, or in a fairly conspicuous fashion, in the case of non-documentary information.

         5. With respect to testimony elicited during depositions, whenever counsel for a Party deems that any question or line of questioning calls for the disclosure of information that should be treated as Confidential Information, counsel may: (i) designate on the record prior to such disclosure that such information is being designated as “Confidential” or (ii) give written notice to all other counsel that such information is being designated as “Confidential” within twenty-one (21) days after receiving a copy of the transcript of the deposition. If a portion of deposition testimony is designated “Confidential, ” the court reporter shall mark that portion of the transcript accordingly in the text of the transcript itself.

         6. Notwithstanding any other provisions in this Order, the Parties reserve the right to withhold from production or otherwise redact in its entirety any information that is subject to protection under a claim of attorney client privilege, the work product doctrine, or any other legally recognized privilege.

         7. Confidential Information shall be used by the receiving Party exclusively in connection with this Action and any appeals thereof. Neither documents containing Confidential Information, nor the Confidential Information contained therein, shall be utilized, copied or reproduced except as needed in connection with this litigation and any appeals thereof. All copies shall be maintained within the possession and control of the Parties' counsel of record, who shall take all reasonable and prudent measures to safeguard the Confidential Information. Any summary or copy of the Confidential Information or the documents containing Confidential Information shall be subject to the terms of this Order. Except as further provided in Section 8 of this Order, neither Party nor its counsel shall in any way, directly or indirectly, publish or disseminate any Confidential Information without the permission of the disclosing Party. The prohibitions in this paragraph include, but are not limited to, any acts to post on a website(s), any acts to publish in any internet “chat room, ” social media, or public discussion site, any acts to provide the information to a journalist, newspaper, magazine, or other publication, and/or any acts otherwise to disseminate the information. Portions of affidavits, deposition transcripts, expert reports, briefs and other court filings quoting, excerpting or summarizing Confidential Information shall be similarly protected from dissemination or disclosure.

         8. The Party receiving any Confidential Information shall not, directly or indirectly, disclose such Confidential Information to any persons other than to the following qualified recipients:

a) The Court, persons employed by the Court, the stenographer transcribing the testimony or argument at a hearing, trial, or deposition in this Action, and any special master or mediator appointed by the court or agreed to by the Parties;
b) Counsel of record for any Party to this Action, as well as employees or independent contractors of such counsel used to assist in the defense or prosecution of this Action;
c) Experts and consultants consulted or retained by any Party or counsel of record for any Party to assist in the defense ...

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