submitted by PHIL HOROWITZ



Attorneys for Plaintiff

 




SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF _______________





STIPULATION AND PROTECTIVE ORDER TO PRESERVECONFIDENTIALITY OF MEDICAL RECORDS AND INFORMATION XXXXXXXXXXXXXXX and DOES ONE through FIFTY, inclusive

Defendants.



STIPULATION

It is hereby stipulated by and between plaintiff XXXXXXXXXXXX and defendants XXXXXXXXXXXXXXXXXXXXXXXX, through their respective counsel of record, as follows.

1. Defendants XXXXXXXXXXXXXXXXXXXXXXXXXXXXXX have obtained and intend to obtain in the future medical records of plaintiff and medical information about plaintiff through discovery in this action. This stipulation and order is intended to preserve the confidentiality of those medical records, the information obtained in them, and any other medical information about plaintiff disclosed by plaintiff in discovery.

2. Defendants and their attorneys of record shall use the medical records of plaintiff obtained through discovery in this case, the information contained in them, and any other medical information about plaintiff disclosed by plaintiff in discovery only for purposes of the present lawsuit.

3. Defendants and their attorneys of record shall not show or disclose any medical records of plaintiff or any medical information about plaintiff obtained through discovery in this case to anyone other than the parties' respective attorneys of record, defendant XXXXXXXXXXXXXXXXXX's in-house counsel, medical consultants and experts (including internal medical personnel), defendant XXXXXXXXXXXXXXXXXXXX and defendant XXXXXXXXXXXX.

4. Before showing or disclosing any medical records of plaintiff or any medical information about plaintiff obtained through discovery in this case, to anyone other than the parties' respective attorneys of record who is permitted by Paragraph 3 to obtain such information, defendants shall obtain the written agreement of the person to whom that information is to be disclosed to be bound by the terms of this stipulation and order and to not disclose the medical records or information protected by this stipulation and order to anyone other than persons who are permitted by Paragraph 3 to obtain such records or information.

5. If the parties in this case file with the Court any medical records protected by this stipulation and order, or file any papers contained information from those medical records or other medical information about plaintiff obtained through discovery, the medical records or other papers shall be filed under seal, with a notation that hose medical records or other papers are confidential and shall not be disclosed to anyone other than Court personnel.

6. This stipulation and protective order shall remain in effect permanently, and shall continue in effect even after this case is finally resolved.

Dated: DEFENSE COUNSEL



by ___________________________

Defense Attorney Attorneys for Defendants

Dated:

LAWLESS, HOROWITZ & LAWLESS

by ____________________________

Phil Horowitz

Attorneys for Plaintiff

IT IS SO ORDERED

Dated:

___________________________

Superior Court Judge