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Civil Rights: Other | New Jersey
Proposed Order
Proposed Order Proposed ESI Protocol by All Defendants. (BAKER, AMANDA)
P.I.: Other | New York Eastern
Order(Other)
ORDER: The Court first addresses the discovery disputes identified in the recent discovery status letter, ECF No. 181 .
As to Defendant's Interrogatory No. 12, Plaintiff need not provide additional information at this time if she is not in possession of it. If Plaintiff learns the information at a later date, she should supplement her interrogatory response. To the extent that Defendant has identified a therapist's name, Plaintiff should confirm whether or not she recalls attending an appointment with this therapist.
As to Plaintiff's gynecological records, Plaintiff must provide unlimited authorizations for all gynecological care providers whom Plaintiff visited during the relevant time period and thereafter. Plaintiff's counsel's attempt to isolate certain information as relevant and other information as irrelevant based on counsel's understanding of possible physiological conditions is not supported by Plaintiff's counsel's area of expertise. Defendant is entitled to a complete set of these medical records so that Defendant's counsel and Defendant's counsel's expert can assess Plaintiff's health, on both a diagnostic and prognostic basis, given that Plaintiff claims injuries based on assaults to these body parts. The Court accepts Defendant's proposal that these materials be designated as attorneys' eyes only at this stage of the case, although it is possible that should this matter go to dispositive motion practice or trial, this designation may need to be modified.
As to the upcoming 9/15/2026 conference, counsel should be prepared to discuss a detailed discovery plan going forward, any remaining discovery disputes, the anticipated area of expert testimony, and counsels' and the parties' availability for a settlement conference from mid-October through mid-December.
Ordered by Chief Mag. Judge Vera M. Scanlon on 9/11/2026. (NTH)
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