Joint Motion for Entry of Stipulated Protective Order

Summary

Roberta Lancione and the 222 other Plaintiffs and Defendant Mass General Brigham Incorporated (MGB) jointly move for an Order approving and entering the Stipulated Confidentiality Protective Order attached as Exhibit 1. The motion says the parties agree that certain information exchanged in discovery is confidential and sensitive corporate information and/or personal information. It says the parties stipulated to the order as an alternative to presenting disputes about production of such information to the Court, and that it is in addition to the Protective Order the Court entered on December 22, 2021. The signature blocks show /s/ Ryan P. McLane for Plaintiffs and /s/ Lynn A. Kappelman for Defendant, dated February 22, 2022.

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Full text

79809710v.1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
ROBERTA LANCIONE, et al.,
Plaintiffs,
v.
MASS GENERAL BRIGHAM
INCORPORATED,
Defendant.
Civil Action No. 1:21-cv-11686
JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER
 Pursuant to Fed. R. Civ. P. 26(c), Roberta Lancione and the 222 other Plaintiffs
(“Plaintiffs”) and Defendant Mass General Brigham Incorporated (“MGB” or “Defendant”),
through their respective counsel, hereby jointly move the Court for an Order approving and
entering the Stipulated Confidentiality Protective Order attached hereto as Exhibit 1.  As grounds
for this joint motion, the parties state as follows:
1.
The parties agree that certain information that has been, or is anticipated to be,
requested and exchanged in discovery in the above-captioned matter constitutes confidential and
sensitive corporate information and/or personal information that must be subject to reasonable
protections against disclosure outside the context of the litigation.
2.
The parties have stipulated to the entry of the attached Stipulated Protective Order
as an alternative to presenting to the Court any disputes regarding the production of such
information.  This Stipulated Protective Order is in addition to the Protective Order that this
Court entered on December 22, 2021.  See Dkt. 60.
WHEREFORE, Plaintiffs and Defendant respectfully request that the Court approve and
enter the Stipulated Confidentiality Protective Order attached hereto as Exhibit 1.
Case 1:21-cv-11686-FDS   Document 67   Filed 02/22/22   Page 1 of 2

2
79809710v.1
Dated:  February 22, 2022
Respectfully Submitted,
/s/ Ryan P. McLane                                      .
Ryan P. McLane (BBO# 697464)
Lauren Bradford (BBO# 700084)
McLane & McLane, LLC
269 South Westfield Street
Feeding Hills, MA 01030
ryan@mclanelaw.com
lauren@mclanelaw.com
TEL: (413) 789-7771
FAX: (413) 789-7731
COUNSEL FOR PLAINTIFFS
  /s/ Lynn A. Kappelman
Lynn A. Kappelman (BBO# 642017)
Katherine E. Perrelli (BBO# 549820)
Kristin McGurn (BBO# 559687)
Dawn Reddy Solowey (BBO# 567757)
SEYFARTH SHAW LLP
Seaport East
Two Seaport Lane, Suite 1200
Boston, MA 02210-2028
kperrelli@seyfarth.com
lkappelman@seyfarth.com
kmcgurn@seyfarth.com
dsolowey@seyfarth.com
TEL: (617) 946-4800
FAX: (617) 946-4801
COUNSEL FOR DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that, on February 22, 2022, this document filed through the CM/ECF
system will be sent electronically to the registered participants as identified on the Notice of
Electronic Filing and paper copies will be sent to those indicated as non-registered participants.
/s/ Lynn A. Kappelman
Lynn A. Kappelman
Case 1:21-cv-11686-FDS   Document 67   Filed 02/22/22   Page 2 of 2

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