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Durbin v. Welcov Healthcare, LLC

United States District Court, D. Montana, Great Falls Division

January 23, 2018

JAMIE DURBIN individually, and as i conservator for his mother, JOAN DURBIN, Plaintiff,
v.
Welcov Healthcare, LLC, Defendant.

          STIPULATED PROTECTIVE ORDER BETWEEN PLAINTIFF AND WELCOV HEALTHCARE, LLC

          Hon. Brian Morris United States District Court Judge.

         Based on the Parties' Stipulation for Protective Order, THE COURT HEREBY ISSUES THE FOLLOWING:

         STIPULATED PROTECTIVE ORDER

         1. Plaintiff hereby warrants, covenants, and agrees that the following documents produced are Confidential Documents subject to the Protective Order:

(1) Unredacted portions of the December 1, 2012 Consulting Services Agreement between Welcov Healthcare, LLC (formerly Mission Health Care, LLC) and Lewiston Healthcare #2, LLC (Bates numbered WEL000024, WEL000026 - WEL000030);
(2) Unredacted portions of the March 1, 1999 Operating Agreement for Welcov Healthcare, LLC (formerly Mission Health Care, LLC) (Bates numbered WEL000013 - WEL000014); and
(3) Unredacted portions of the May 15, 2017 First Amendment to the Limited Liability Company Agreement of Welcov Healthcare, LLC (Bates numbered WEL000021 - WEL000022).

         Should the Party to whom Confidential Document(s) or Confidential Information has been produced wish to thereafter disclose those Confidential Document(s) or Confidential Information publicly and for any purposes outside the above-captioned litigation, the Party shall first provide the Party who produced the Confidential Document(s) or Confidential Information with a written request containing:

(a) The Confidential Document(s) or Confidential Information the Party desires to disclose;
(b) The identity of the person(s) to whom the Party intends to disclose the Confidential Document(s) or Confidential Information; and
(c) The Party's reason for disclosure of the Confidential Document(s) or Confidential Information.

         If the Party who produced the Confidential Document(s) or Confidential Information does not consent to their disclosure within a reasonable amount of time, the requesting Party may, at its sole discretion, move the Court for an Order allowing release of the designated Confidential Document(s) or Confidential Information publicly subject to reasonable conditions.

         2. A Party to whom a Confidential Document has been produced through discovery shall not give, distribute, disclose and/or otherwise reveal that Confidential Document to any non-party unless such distribution or disclosure is necessary for the prosecution of the claims herein or the defense to those claims and unless the non-party to whom such necessary ...


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