Order: Transformative Healthcare Inc vs. Tyler, Patrick Sean

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x 9 SUFFOLK, SS. SUPERIOR COURT DEPARTMENT

 

      

Q 3 BUSINESS LITIGATION SESSION
‘ CIVIL ACTION NO. 2084-CV-02375- \a\i4
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‘TRANSFORMATIVE HEALTHCARE, INC. _) OX OF ay
and FALLON AMBULANCE SERVICES, LLC, ) Et
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Plaintiffs -
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y PARICK SEAN TYLER and RANDESCO, LLC, ) 2
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Defendants. ) Ui
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DEFENDANTS’ MOTION FOR ENTRY OF PROTECTIVE ORDER
PURSUANT TO MASS. R. CIV. P. 26(c)

Pursuant to Mass. R. Civ. P. 26(c), Defendants respectfully move this Court to enter the

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AVE Ody ionrterag

Proposed Protective Order, attached hereto as Exhibit 1. In support of this Motion, Defendants

state the following:

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1. In an effort to address confidentiality concerns of all parties and to ensure that the
present litigation may progress in a timely and efficient fashion, counsel for the parties engaged
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a good faith efforts to negotiate a mutually acceptable Stipulated Protective Order. In this

regard, the parties agreed that Exhibit 1 may be entered as such an Order, except that Plaintiffs

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efuse to agree to the highlighted language in Sections 3.10 and 10.2. Without such language,

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owever, Defendants would be precluded from sharing confidential information with (i) in-house

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