Re: [Case Name]


As you are aware, certain medical information and perhaps medical records regarding plaintiff [PLTFF NAME] are relevant to the subject matter of this action. Defendants have requested production of confidential medical records. I would also not be at all surprised if some of the deposition questions asked for confidential medical information.

Defendants may be entitled to discover some medical information and perhaps some medical records regarding [PLTFF NAME]. At the same time, [PLTFF NAME] is entitled to have the privacy of confidential medical records and information preserved. To attempt to accommodate both of these interests, I have drafted a proposed stipulation and protective order for your review and consideration. A copy is enclosed.

Please review the proposed stipulation and protective order and, if it meets with your approval, sign it in counterparts and return them to me for submission to the Court. I suggest that we take care of this matter before [PLTFF NAME]'s deposition begins to avoid unnecessary discovery disputes.

If you have any questions or proposed changes, please contact me as soon as possible. Thank you in advance for your consideration of the proposed stipulation and protective order.

Very truly yours,

Phil Horowitz