Free Protective Order - District Court of Connecticut - Connecticut

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I I THE UNITED STATES DISTRICT COQRT I I
· DISTRICT OF CONNECTIC‘ I; _
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l PAUL SANGALLI, I: I _
g Plaintiff, Q _ I
I v. I CIVIL NO; BIOBCV 0403(CFD) I
I JOHN ASHCROFT Q I . _ I
ATTORNEY GENERAL OF THE : .
, UNITED STATES, UNITED STATES :
DEPARTMENT OF JUSTICE : Q R
Defendant. I *
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PRIVAC ACT PROTECTIVE •‘¤E'I I
The defendant, with consent of plaintiffws coInsel, has '
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submitted a motion for a protective order i» thisIactio pursuant
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to Rule 26(c). This is an employment discriminatioh action wherein I
the parties may be required to disclose info matiod whic is or may I
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be encompassed by the Privacy Act of 1974, 5 u.sIc. § 552a. In '
order to permit the disclosure of information feleva t to the ,
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subject matter of this case without making t is iniormatlon public _
and thus undermining the purpose of the Priv=cy·AcI, pur uant to 5
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U.S.C. § 552a(b)(11) and Rule 26(c), Fed.R Civ.PI, it is hereby i
Ordered as follows: I _ I
1. The parties are authorized to disclo—e te ehch other and to
this Court Privacy Act information, which in·ludesarecor s subject _
to the Privacy Act, including all docu ents Iand erivative I
information so designated by the producing •r oriiinati g party.
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. ‘ Case 3:03-cv-0 :; % -CFD Document14 Fi|ed1 Pag 2of4
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E 2. Documents obtained by plaintiff f omésokrces other than
I defendant are not Privacy Act informat'oné sxbjec to this
` protective order. E i I
( 3. Information that is believed to be subjeit to he Privacy !
Act shall be so designated as follows: ocumekts w'll be so
designated in writing; and deposition transc ipts Fy in icating on i
the record or by subsequent writing. · = E
4. If a party disputes such designa ion 0% con ends that
such designation should have been made when it wds not made, the
parties may submit the matter to the Court fo resoiution, but only Q
if counsel for the parties are unable to res ive their d fferences
informally. Q
5. Documents containing Privacy Act inforiation shall be
held in strict confidentiality and may be us d solely fo purposes g
of this litigation. The parties, their couns l, an? thos employed l
by them shall limit the making of copies of such iecord to those g
necessary to their activities in pursu ng dhe l tigation. {
Documents containing Privacy_Act informatio and ill co ies shall 5
be returned `to the producing party wit in 6D day? of the
termination of this litigation, including a y app%als. I
6. Privacy Act information may be iscloded on y to the E
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following persons, who must be informed f the term of this \
U Protective Order prior to disclosure: 1
(a) The parties to this litigati n, thdir at orneys of i
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’ l; .` K Cas_e.3:O3—cv-Q, _,;Q§QD Qocument 14 Filed 1% , /QOOJF Pag1e3of4
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Q record, and persons regularly in the emp oyiof such attorneys
l having a need for the information in the petfo mano of their
{ duties; T i
i _ (b) Testifying or consulting expert witkesse and those {
regularly in their employ having a need for he information in the Q
performance of their duties; U !
(c) Deposition witnesses, potentia deposition itnesses,
U trial witnesses, potential trial witnessea, .and attorneys for E
potential deposition and trial witnesses; a d R I
(d) Court reporters used in conne·ti©n with t is action 5
and those regularly in their employ having a need for the i
information in the performance of their dut'es. Q
7. Should either party wish to •isclo%e Pr vacy Act X
information to any persons except those indicated in p ragraph 5 I
above, counsel for the opposing party shal be advised. If the
opposing party does not consent to the disc osurei then the party
seeking disclosure may, on motion, seek modiiicatiin of his Order
from the Court. I
8. Documents containing Privacy Act information shall be i
filed with the Court accompanied by a motio to sdal, p rsuant to 3
the Local Rules, and maintained under seal by tie Cle k of the
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Court. [ i
9. Nothing in this Protective Order affects Lhe rip ht of the
parties to confer with counsel with respec to ¥ny P ivacy Act Q
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information, nor does this Protective rder iconSt`tute any i
I agreement or ruling as to the discoverabili y or %dmiSS'bility of I
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any document or information. Q I I
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So ORDERED I I
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, 2003 . I
U r ii’` ` 0*2;; ~ii ;I,§;;.;;;?‘€Q I
OPHER F. ·•· I I
UNITED STATES DISTRICT JUDGE
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