United States District Court, D. Minnesota
Judy Larson, Janelle Mausolf, and Karen Reese, individually and on behalf of themselves and all others similarly situated, Plaintiffs,
Allina Health System; the Allina Health System Board of Directors; the Allina Health System Retirement Committee; the Allina Health System Chief Administrative Officer; the Allina Health System Chief Human Resources Officer; Clay Ahrens; John I. Allen; Jennifer Alstad; Gary Bhojwani; Barbara Butts-Williams; John R. Church; Laura Gillund; Joseph Goswitz; Greg Heinemann; David Kuplic; Hugh T. Nierengarten; Sahra Noor; Brian Rosenberg; Debbra L. Schoneman; Thomas S. Schreier, Jr.; Abir Sen; Sally J. Smith; Darrell Tukua; Penny Wheeler; Duncan Gallagher; Christine Webster Moore; Kristyn Mullin; Steve Wallner; John T. Knight; and John Does 1- 20, Defendants.
N. Leung United States Magistrate Judge
matter comes before the Court on the parties' Stipulation
for Protective Order (“Stipulation”) (ECF No.
80). Pursuant to the parties' Stipulation and Federal
Rule of Civil Procedure 26(c), IT IS HEREBY
ORDERED that confidential information shall be
disclosed only in the following designated ways:
used in the Protective Order, these terms have the following
(a) “Attorneys” means counsel of record;
(b) “Confidential” and “Confidential -
Attorneys' Eyes Only” documents are documents
designated pursuant to Paragraph 2;
(c) “Documents” are all materials within the
scope of Fed.R.Civ.P. 34;
(d) “Outside Vendors” means, by way of example,
messenger, copy, coding, and other clerical-services vendors
not employed by a party or its Attorneys;
(e) “Party” means either named Plaintiffs or
named Defendants and their counsel, and “Parties”
means all named Plaintiffs and their counsel and all named
Defendants and their counsel; and
(f) “Written Assurance” means an executed
document in the form attached as Exhibit A.
Party may designate a document “Confidential” or
“Confidential - Attorneys' Eyes Only” to
protect information within the scope of Fed.R.Civ.P. 26(c).
Documents, discovery responses, testimony, tangible things,
or other information may be designated Confidential
regardless of how generated, stored, or maintained if the
Producing Party reasonably and in good faith believes that
such material contains or reflects information that
constitutes confidential, non-public, proprietary,
commercially sensitive, or private information of an
individual or entity. Documents, discovery responses,
testimony, tangible things, or other information may be
designated “Confidential - Attorneys' Eyes
Only” regardless of how generated, stored, or
maintained if the Producing Party reasonably and in good
faith believes that such material contains or reflects: (a)
highly sensitive financial information of an individual or
entity; (b) highly sensitive personal information (e.g.
social security numbers); (c) trade secrets; or (d)
competitively-sensitive information that meets the
requirements for protection from public filing.
“Confidential” and “Confidential -
Attorneys' Eyes Only” documents, along with the
information contained in the documents, shall be used solely
for the purpose of this action, and no person receiving such
documents shall, directly or indirectly, use, transfer,
disclose, or communicate in any way the documents or their
contents to any person other than those specified in this
Protective Order. If any other use is sought, the requesting
party or third party must file a motion to amend the
Protective Order in compliance with Local Rule 7.1.
Access to any Confidential document shall be limited to:
(a) the Court and its staff;
(b) Attorneys, their law firms, and their Outside ...