Opinion
No. 2:11-cv-01655-MCE-DAD
07-29-2012
RITCHARD MOLINA, Plaintiff, v. EASTERN PLUMAS HEALTH CARE, an unknown business entity, EASTERN PLUMAS HEALTH CARE FOUNDATION, INC., a California corporation, Defendants.
LAW OFFICES OF JEREMY PASTERNAK Jeremy Pasternak Attorneys for Plaintiff RITCHARD MOLINA SCHUERING ZIMMERMAN & DOYLE, LLP Michael J. Campbell Attorneys for Defendant EASTERN PLUMAS HEALTHCARE DISTRICT
ROBERT H. ZIMMERMAN, Bar No. 84345
MICHAEL J. CAMPBELL, Bar No. 279345
SCHUERING ZIMMERMAN & DOYLE, LLP
Attorneys for Defendant EASTERN PLUMAS HEALTHCARE DISTRICT
STIPULATED PROTECTIVE ORDER
GOVERNING DISCLOSURE AND
PRODUCTION OF CONFIDENTIAL
AND OTHER DOCUMENTS AND
INFORMATION
IT IS HEREBY STIPULATED by and between counsel to the parties, that the following matters are subject to this Protective Order:
1. That all medical and employment records being produced by all parties in this action, be and will remain at all times protected, privileged, sensitive, and/or proprietary. The documents being produced, may include but may not be limited to medical records, employment history records, contracts between the parties or portions thereof, personnel records, manuals, business policies and manuals, reports, photos, videos and written statements.
2. It is agreed between the parties and through their counsel that all medical and employment records produced in the course of this litigation shall remain confidential and will be used solely in the prosecution or defense of the subject litigation and will not be disseminated, disbursed, or otherwise given to any person or entity outside of the litigation at any time.
3. Documents and information produced may be provided to experts or consultants as necessary to prosecute or defend the litigation with the same agreement that such documents are not to be used by any other person outside the matter of Molina v. Eastern Plumas Health Care, et al.
LAW OFFICES OF JEREMY PASTERNAK
By: _________________
Jeremy Pasternak
Attorneys for Plaintiff
RITCHARD MOLINA
SCHUERING ZIMMERMAN & DOYLE, LLP
By: _________________
Michael J. Campbell
Attorneys for Defendant EASTERN
PLUMAS HEALTHCARE DISTRICT
ORDER
IT IS SO ORDERED.
_________________
DALE A. DROZD
UNITED STATES MAGISTRATE JUDGE