I, the undersigned, do hereby authorize the above named care provider to release any and all information relating to me, to communicate with and to permit Ogletree, Deakins, Nash, Smoak & Stewart, P.C., or any agent or employee thereof, to obtain, inspect, and copy any medical record or records of my condition or treatment, including but not limited to reports, treatment for alcohol or drug abuse, physical therapy, nutrition, occupational rehabilitation, mental health, psychologists, prosthesis, and psychiatric records, and films of diagnostic imaging such as x-rays, CT scans, MRIs, etc., while a patient of or under treatment by said care provider, and I further authorize said care provider to permit Ogletree, Deakins, Nash, Smoak & Stewart, P.C., or any agent or employee thereof, to obtain and make copies of all such records.
The court acknowledges that it has not drawn these lines with the precision litigants and their counsel typically seek. But the difficulty of drawing sharp lines of relevance is not a difficulty unique to the subject matter of this litigation or to social networking communications. Lawyers are frequently called upon to make judgment calls-in good faith and consistent with their obligations as officers of the court-about what information is responsive to another party's discovery requests. Discovery is intended to be a self-regulating process that depends on the reasonableness and cooperation of counsel. Fed.R.Civ.P. 37(a)(1). Here, in the first instance, the EEOC's counsel will make those determinations based on the guidelines the court has provided. As with discovery generally, Simply Storage can further inquire of counsel and the claimants (in their depositions) about what has and has not been produced and can challenge the production if it believes the production falls short of the requirements of this order. Nothing in this Order is intended to foreclose such follow-up procedures. Moreover, this Order does not prevent Simply Storage from seeking additional materials should discovery suggest they are probative of a claim or defense.
Application for employment; offer of employment; employment agreement; documents reflecting my job performance including any achievements, commendations, attendance, and discipline; any work accommodations provided to me; reason(s) for my departure from employment; summary of wages, salary or other compensation received by me; and summary of benefits received by me.
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