Filed: Oct. 18, 2019
Latest Update: Oct. 18, 2019
Summary: STIPULATED PROTECTIVE ORDER RICARDO S. MARTINEZ , Chief District Judge . I. STIPULATION IT IS HEREBY STIPULATED by and between the parties as follows: 1. This is a personal injury case in which the Plaintiff's physical and/or mental condition and health care are in issue. In connection with discovery of Plaintiff's health care records, the parties hereby stipulate to and request that the court enter the subjoined order. DATED: October 18, 2019. For the Plaintiff:
Summary: STIPULATED PROTECTIVE ORDER RICARDO S. MARTINEZ , Chief District Judge . I. STIPULATION IT IS HEREBY STIPULATED by and between the parties as follows: 1. This is a personal injury case in which the Plaintiff's physical and/or mental condition and health care are in issue. In connection with discovery of Plaintiff's health care records, the parties hereby stipulate to and request that the court enter the subjoined order. DATED: October 18, 2019. For the Plaintiff: ..
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STIPULATED PROTECTIVE ORDER
RICARDO S. MARTINEZ, Chief District Judge.
I. STIPULATION
IT IS HEREBY STIPULATED by and between the parties as follows:
1. This is a personal injury case in which the Plaintiff's physical and/or mental condition and health care are in issue. In connection with discovery of Plaintiff's health care records, the parties hereby stipulate to and request that the court enter the subjoined order.
DATED: October 18, 2019.
For the Plaintiff: For the Defendant:
s/Robert Bohm s/John T. Kugler
Robert Bohm, WSBA #42703 John T. Kugler, WSBA # 19960
Jesse Froehling, WSBA #47881
II. ORDER
1. All of the Plaintiff's health care records received by the Defendant through discovery in this matter are governed by terms of this stipulation and order.
2. Health care records shall be used solely for the purpose of this lawsuit and for no other purpose.
3. Health care records may be disclosed only to the following persons:
a. The parties to this action and the parties' claims representatives;
b. Counsel for the parties and counsel's agents and employees;
c. Court reporters who are involved in depositions, the trial, or any hearings in this action;
d. Experts, independent contractors, consultants or advisors who are employed or retained by or on behalf of one or more of the parties or their counsel to assist in the litigation of this action;
e. Deponents and their counsel who have a need to review the records during the course of, or in connection with depositions taken in this action;
f. Witnesses in this action who need to review the records in connection with their testimony in this action; and
g. Arbitrators and/or mediators involved in the this case.
4. Health care records filed by the parties through the CM/ECF system shall be filed under seal.
5. This order does not apply to health care records offered as exhibits at the time of trial.
6. This order does not preclude Plaintiff from filing a motion to deal with the public disclosure of her confidential medical records.
7. This order does not preclude the Plaintiff from filing a motion addressing the discoverability of any particular health care records.
8. The termination of the proceedings in this action shall not relieve the parties of the obligation to maintain the confidentiality of Plaintiff's health care records unless the court orders otherwise.
PRESENTED BY:
TURNER KUGLER LAW, PLLC
By: s/John T. Kugler
John T. Kugler, WSBA # 19960
Attorney for Defendant
