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FIAMM Technologies, LLC v. Blue Cross Blue Shield of Michigan

United States District Court, E.D. Michigan, Southern Division

December 15, 2016

FIAMM TECHNOLOGIES, LLC AND FIAMM TECHNOLOGIES, LLC GROUP HEALTH PLAN, Plaintiffs,
v.
BLUE CROSS BLUE SHIELD OF MICHIGAN, Defendant.

          VARNUM LLP Attorneys for Plaintiffs By William L. Thompson

          HICKEY HAUCK BISHOFF & JEFFERS, PLLC Attorneys for Defendant By Benjamin W. Jeffers

          STIPULATED PROTECTIVE ORDER

          ROBERT H. CLELAND UNITED STATES DISTRICT JUDGE

         WHEREAS, the parties consider certain information and documents in their possession to be confidential and proprietary, including, inter alia, sensitive financial, commercial, business, and medical information and, therefore, mutually desire that a protective order limiting the use, access to and disclosure of such information and documents be entered, and the Court being otherwise fully informed;

         IT IS HEREBY ORDERED that, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the production and use of documents and information produced or made available in this matter shall proceed in accordance with the following terms:

         I. SCOPE OF THE ORDER

         1. Scope of Order: This Order applies to all documents (and the contents thereof) served, transmitted, or incorporated in this lawsuit pursuant to Rules 26 through 36 and/or Rule 45 of the Federal Rules of Civil Procedure.

         II. DESIGNATION OF MATERIALS AS “CONFIDENTIAL” ORATTORNEYS EYES ONLY”

         2. Confidential Designation: The supplying party (including third-parties) may designate material (including paper or electronic documents, written discovery responses, and/or deposition testimony or exhibits) as “Confidential” if such party believes in good faith, and after reasonable inquiry, that such material is entitled to protection under Rule 26, or any other applicable law. Medical information protected by the Health Insurance Portability and Accountability Act Privacy Regulations, 45 CFR § 164.512(e), is entitled to protection and is treated as though designated as Confidential regardless of whether it is designated Confidential by the supplying party. Nothing in this Order is intended to expand the scope of materials entitled to protection beyond what is covered by Rule 26 or other applicable law.

         If BCBSM produces any electronically-stored information as previously produced in Hi-Lex marked “Confidential” and/or “Attorney Eyes Only, ” BCBSM may keep those designations in this case, but the designations are withdrawn as to (a) designated documents in the Hi-Lex materials that were later de-designated in Hi-Lex, or (b) documents that are dated 2009 or earlier. As to the remaining designations, Plaintiffs may identify specific documents, or reasonably ascertainable categories of documents, that it wants de-designated and BCBSM shall promptly review those documents to determine, and report to Plaintiffs, whether it will continue the designations in accordance with the terms of this order.

         3. Persons Eligible to View Confidential Information: Only Qualified Persons are authorized to view confidential information in this case, who are:

a. Attorneys of record in this litigation and secretaries, paralegals, law clerks and support staff employees to whom, in the opinion of the attorney of record for the receiving party, it is necessary that the information be disclosed for purposes of this litigation;
b. Any person who is not an employee or business consultant of a party and who is retained by a party or its attorneys of record in this litigation solely as an independent expert for the purposes of this litigation and who agrees in writing to be bound by the terms of this Protective Order. The independent expert must complete and sign a Confidentiality Statement in the form of Exhibit A, attached hereto. A copy of that Statement must be given to the other party before access is allowed to the Confidential information.
c. Officers, directors, and/or employees expressly designated by each party, who, by accepting said designation agree to be bound by the terms of this Protective Order.
d. Any person that an attorney of record in this litigation reasonably believes needs to review the confidential information to enable the good faith prosecution or defense of this litigation, such as a potential witness. Any such person shall complete and sign a Confidentiality Statement in the form of Exhibit A, attached hereto. A copy of that Statement ...

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