Whitley v. Baptist Health

          Robert L. Henry, IIII, James D. Robertson, Barber Law Firm PLLC, Attorneys for the Baptist Defendants and Defendant Diamond Risk Insurance LLC.

          David P. Glover, David Chan Jung, Wright, Lindsey & Jennings LLP, Attorneys for Defendant Continental Casualty Company.

          Campbell & Grooms, PLLC, Donald K. Campbell, III BAILEY & OLIVER LAW FIRM, Sach D. Oliver, Frank H. Bailey, T. Ryan Scott, Geoff D. Hamby, HENINGER GARRISON DA VIS LLC, W. Lewis Garrison Jr., Erik S. Heninger, Jeffrey P. Leonard, Attorneys for Plaintiff.

          Jeffrey W. Puryear, Ryan M. Wilson, Womack Phelps, Puryear Mayfield & McNeil, P.A., Attorneys/or RevClaims. LLC.

          AMENDED AGREED PROTECTIVE ORDER

          Hon. D.P. Marshall, United States District Judge.

         The purpose of this amendment is to extend the confidentiality protections and obligations of the existing Agreed Protective Order (Dkt. # 55) to documents and information obtained from any non-parties to this litigation, including non-party RevClaims, LLC. The parties to this case and all other non-party signatories to this Order agree to protect the confidentiality of certain information (including deposition testimony) and documents (including documents stored in electronic format) that may be discovered or offered into evidence at the trial of this case. The parties and signatories agree that the confidentiality of such information and documents shall be preserved under the terms of this Protective Order:

         1. It is agreed that material provided by any of the parties or signatories, which they deem confidential, shall be disclosed only to the following individuals, each of whom shall be required to read this Protective Order and agree to abide by these terms before being given any of the information:

a. Counsel for plaintiff and counsel for defendants engaged in this litigation and their respective staff, to the extent reasonably necessary:

b. The parties to the litigation, including their employees, employers and experts;

c. All witnesses, whether testifying in depositions, hearings, or at trial;

d. Court personnel, any mediator involved in this action, and employees of any such mediator; and

e. Any other individuals included by order of the Court.

         Documents produced by the parties or signatories to which this Protective Order is applicable shall be stamped "CONFIDENTIAL."

         2. The inadvertent production, without designation as confidential, of information or a document intended to be designated as confidential shall not waive the producing entity's right to so designate such document or information. Any information or documentation that is inadvertently produced without being designated as confidential shall be, upon written ...