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United States ex rel. White v. Mobile Care EMS

United States District Court, S.D. Ohio, Western Division

November 20, 2019

UNITED STATES OF AMERICA ex rel. BRANDEE WHITE, et al., Plaintiffs,
v.
MOBILE CARE EMS & TRANSPORT, INC., et al, Defendants.

          James B. Helmer, Jr., Robert M. Rice, Erin M. Campbell, James A. Tate Helmer, Martins, Rice & Popham Co., LPA Attorneys for Relators Brandee Wliite, Laura L. Cunningham, and Jeffery Wisler

          Margaret A. Castro Assistant United States Attorney

          Chad R. Ziepfel Sanna-Rae Taylor TAFT STETTINIUS & HOLLISTER LLP Attorneys for Defendant Mobile Care EMS & Transport, Inc.

          Carolyn A. Taggart, Kathleen M. Brinkman, Zachary A. El-Sawaf Porter Wright Morris & Arthur LLP Attorneys for Defendant LogistiCare Solutions, LLC

          Susan J. Dlott, Judge.

          STIPULATED PROTECTIVE ORDER

          Karen L. Litkovitz, Magistrate Judge.

         Plaintiff United States of America, Plaintiffs/Relators Brandee White, Laura L. Cunningham, and Jeffery M. Wisler, Defendant Mobile Care EMS & Transport, Inc., and Defendant LogistiCare Solutions, LLC (each a "Party" and together, the "Parties") desire to facilitate discovery in this matter while preserving their private, confidential, and proprietary information as defined herein and, therefore, move the Court to adopt this Stipulated Protective Order. Pursuant to Rules 26 and 29 of the Federal Rules of Civil Procedure, it is agreed by the Parties, and hereby ORDERED, ADJUDGED, and DECREED, by this Court, that:

         1. Scope.

         This Stipulated Protective Order (the "Order") governs the handling of documents, testimony, and other information, including all copies, excerpts, and summaries thereof, defined below as "Confidential Material," that the Parties produce or that any nonparties produce in this action pursuant to a subpoena. This Order also governs filing of documents. This Order is a qualified protective order, as defined in 45 C.F.R. §164.512(e)(1)(v), in that the Order prohibits the Parties from using or disclosing Protected Health Information ("PHI"), as defined under the Health Insurance Portability and Accountability Act of 1996, Pub. L. 104-191, and the applicable regulations at 45 C.F.R. Parts 160, 162, and 164, for any purpose other than this action, and further requires the return or destruction of PHI (including all copies made) at the conclusion of the action.

         2. Confidential Material Defined.

         Any documents or information that a Party believes in good faith contains PHI; private information the confidentiality of which the asserting party has an obligation, legal duty, or right to protect; or trade secrets, confidential research, development, or commercial information, may be designated as Confidential Material subject to this Order and shall not be used except in connection with the litigation of this case as authorized by this Order. Under these same conditions any nonparty in receipt of a subpoena issued in this case may also designate any documents, electronic information, or testimony that they produce as Confidential Material that will be subject to this Order.

         3. Access to Confidential Material.

         Confidential Material produced by a Party or nonparty may be inspected only by the Parties, their counsel, paralegals and clerical employees of the Parties' counsel, designated persons retained by the Parties to furnish expert services or advice or to give expert testimony in this Action, and deposition or trial witnesses. Designated experts shall not inspect or review any Confidential Material until they have signed the Acknowledgment (attached hereto as Exhibit A) prior to reviewing the Confidential Material or have been so instructed by the Court in the case of trial witnesses. Any additional disclosure of Confidential Material shall take place only pursuant to agreement of counsel, or, absent agreement, pursuant to an order of the Court upon motion duly made. Nothing herein shall preclude or prevent the Parties from using their own Confidential Material for any purpose in any fashion.

         4. Manner ...


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