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Holloway v. Sessions

United States District Court, M.D. Pennsylvania

November 3, 2017

RAYMOND HOLLOWAY, JR., Plaintiff
v.
JEFFERSON B. SESSIONS III, et al. Defendants.

          PROTECTIVE ORDER

          Hon. Christopher C. Conner Chief Judge

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the following Protective Order has been entered by the Court.

         1. Protectable Information.

         Information within or derived from the following categories of information constitutes "Protectable Information": (a) documents containing personally identifiable information, such as social security numbers, birth dates, home addresses, email addresses, and non-public telephone numbers; (b) documents filed under seal in other courts proceedings; (c) mental health records; (d) any records concerning criminal charges against Plaintiff Raymond Holloway subject to expungement as a matter of law.

         2. Designation of Protected Information.

         For Protectable Information to be subject to this order, the party producing the Protectable Information shall stamp or otherwise affix the following label to documents containing such information: "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER." For Protectable Information stored in a medium that makes such stamping impracticable (such as computer data), the casing, housing, and/or accompanying letter producing that information shall be stamped or otherwise indicate that the media is "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER." Portions of depositions, sworn statements, or other discovery responses containing Protectable Information shall be subject to this order if, within 14 days of the transcription of such information, a counsel for a party (1) identifies these portions by page number, and where applicable line, paragraph, or response number, as "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER, " and (2) provides notice to all persons in known custody of such information of such designation. All Protectable Information designated as "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" as well as information copied or derived therefrom constitutes "Protected Information" for purposes of this order. Information that a party has previously disclosed publicly generally should not be protected by that party under this Protective Order. Should the non-producing party identify information designated as "CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER" that it believes is public in nature such that the Protective Order should not apply, the non-producing party should bring that to the attention of the producing party and meet-and-confer before seeking relief from the Court.

         3. Failure to Designate.

         The failure to designate information as Protected Information shall not constitute a waiver of an assertion by the party producing the Protectable Information that the Protectable Information may later be subject to this order.

         4. Restrictions on the Disclosure of Protected Information.

         Protected information may be disclosed only to "Qualified Recipients, " who consist of (a) this Court and/or any appellate or other tribunal responsible for adjudicating claims related to this action, including their respective personnel, as well as court reporters; (b) counsel for the parties, including agency counsel for defendants; (c) personnel regularly in the employ of counsel for the parties who have a need for the Protected Information in the performance of their duties in conjunction with this action; (d) parties to this action who have a need to review the Protected Information for the purposes of this case; (e) consultants and expert witnesses consulted, retained, or hired by any party to this litigation, only to the extent that they require Protected Information to elicit their expert report, opinion, testimony, and/or consultation regarding this litigation.

         5. Permissible Uses of Protected Information.

         Qualified recipients shall use Protected Information received from another party or entity only for purposes of this litigation and shall not disclose Protected Information except as provided in paragraph 4. A party will not be restricted in its use or dissemination of the Protected Information that it produces in this case.

         6. Agreement to Be Bound by Protective Order.

         Before receiving any Protected Information, Qualified Recipients, except those identified in sections (a) and (b) of paragraph 4 above, shall execute a copy of the Agreement to Be Bound by Protective Order in the form attached hereto (the "Agreement Form"). Counsel for the parties who received Protective Information from another party or entity shall maintain executed Agreement Forms for each person receiving Protected Information. Upon ...


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