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Eberhardinger v. City of York

United States District Court, M.D. Pennsylvania

April 19, 2018

ERIKA EBERHARDINGER, Plaintiff
v.
CITY OF YORK, BENJAMIN SMITH, MATTHEW FOSTER, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, STATE FARM FIRE & CASUALTY COMPANY, STATE FARM INSURANCE COMPANY, STATE FARM COMPANIES, STATE FARM, And STATE FARM INSURANCE, Defendants.

          ARM. Lawyers Joshua B. Goldberg, Esq. Attorney for Plaintiff

          William J, Ferren & Associates Leticia J. Santiago, Esq. Attorney for Defendants, Smith and City of York

          CONFTDENTIALITY STIPULATION AND PROTECTIVE ORDER

          THE HONORABLE CHRISTOPHER C. CONNER UNITED STATES DISTRICT JUDGE

         WHEREAS, defendant City of York intends to produce certain documents pursuant to Rule 26 of the Federal Rules of Civil Procedure that it deems to be confidential or otherwise inappropriate for public disclosure; and

         WHEREAS, defendant City of York will only produce these documents if appropriate protection for their confidentiality is assured; and

         WHEREAS, good cause exists for the entry of an order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure;

         NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the attorney for plaintiff and defendants, as follows:

         1. As used herein, "Confidential Materials" shall mean personnel records of Police Officer Benjamin Smith, and other documents that may, during the pendency of this litigation, be designated "Confidential Material" by defendants or the Court, except that such documents and information shall not be deemed "Confidential Materials" to the extent, and only to the extent, that they are (a) obtained by plaintiff from sources other than defendants, or (b) are otherwise publicly available.

         2. Neither Plaintiffs attorney nor Co-Defendants' atttorneys shall use the Confidential Materials for any purpose other than for the preparation or presentation of their case in this action.

         3. Neither Plaintiffs attorney nor Co-Defendants' attorneys shall disclose the Confidential Materials to any person not a member of the staff of their law office, except under the following conditions:

a. Disclosure may be made only if necessary to the preparation or presentation of their case in this action.
b. Disclosure before trial may be made only to Plaintiff and Co-Defendants', to an expert who has been retained or specially employed by Plaintiffs attorney or Co-Defendants' attorneys in this action in anticipation of litigation or preparation for this action, to a witness at deposition, or to the Court.
c. Before any disclosure is made to a person listed in subparagraph (b) above (other than to the Court), the attorney shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in writing, in the form annexed hereto as Exhibit A. not to use the Confidential Materials for any purpose other than in connection with the prosecution of this case and not to further disclose the Confidential Materials except in testimony taken in this case. The signed consent shall be retained by the attorney and a copy shall be furnished to Defendant City of York's attorneys upon their request.

         4. Deposition testimony concerning any Confidential Materials that reveals the contents of such materials shall be deemed confidential, and the transcript of such testimony, together with any exhibits referred to therein, shall be separately bound, with a cover page prominently marked "CONFIDENTIAL." Such portion of the transcript shall be ...


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