IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

LUMBERMAN’S UNDERWRITING * 

ALLIANCE and CAMBRIDGE * 

INTEGRATED SERVICES GROUP, INC. * 

as Subrogees of TRANSPORT LEASING/ * 

CONTRACT, INC.; HANSEN & ADKINS * 

AUTO TRANSPORT, * 

 * 

 Plaintiffs, * 

 * 

vs. * Civil Action No.3:06-CV-645-MEF 

 * 

EMORY LEE YOUNG * Formerly Russell County Circuit 

an individual, * Court Case No: CV-06-224 

 * 

 Defendants. * 

MOTION FOR PROTECTIVE ORDER

 COMES NOW the defendant, Emory Lee Young and respectfully moves this Court to 

enter a protective order to assist the parties in compliance with the requirements of HIPAA 

Privacy Rules, 45 C.F.R. § 164.512(e). The standard language HIPAA Consent Order is 

attached hereto as Exhibit A. 

 WHEREFORE, PREMISES CONSIDERED, the parties respectfully request that this 

Court enter a protective order expressly authorizing disclosure of protected health information by 

the parties and third parties to counsel for the parties. 

 Respectfully Submitted, 

 

 

 /s/ Joshua J. Jackson_________________ 

 Joshua J. Jackson (JAC072) 

Case 3:06-cv-00645-MEF-TFM Document 6 Filed 09/26/2006 Page 1 of 2
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OF COUNSEL: 

SAMFORD & DENSON, LLP 

P. O. Box 2345 

Opelika, Alabama 36803-2345 

Phone: (334) 745-3504 

Facsimile: (334) 745-3506 

CERTIFICATE OF SERVICE

 I hereby certify that on September 26, 2006 I electronically filed the foregoing with the 

Clerk of Court using the CM/ECF system which will send notification of such filing to the 

following: 

Michael S. Jackson 

Ryan Wesley Shaw 

Beers, Anderson, Jackson, Patty & Van Heest, P.C. 

P.O. Box 1988 

Montgomery, AL 36102-1988 

 

 /s/ Joshua J. Jackson______________ 

 OF COUNSEL 

Case 3:06-cv-00645-MEF-TFM Document 6 Filed 09/26/2006 Page 2 of 2
IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

EASTERN DIVISION 

LUMBERMAN’S UNDERWRITING * 

ALLIANCE and CAMBRIDGE * 

INTEGRATED SERVICES GROUP, INC. * 

as Subrogees of TRANSPORT LEASING/ * 

CONTRACT, INC.; HANSEN & ADKINS * 

AUTO TRANSPORT, * 

 * 

 Plaintiffs, * 

 * 

vs. * Civil Action No.3:06-CV-645-MEF 

 * 

EMORY LEE YOUNG * Formerly Russell County Circuit 

an individual, * Court Case No: CV-06-224 

 * 

 Defendants. * 

CONSENT HIPAA ORDER

 Upon compliance with Alabama and federal law, the attorneys for the parties and/or pro 

se parties to this lawsuit are permitted to obtain all health information, including charges 

therefor, relating to James John; DOB: 10/20/1938. This Order neither broadens nor restricts 

any party’s ability to conduct discovery pursuant to Alabama and Federal law, the sole purpose 

hereof being only to permit compliance with the Health Insurance Portability and Accountability 

Act of 1996 (HIPAA). Subject to the applicable provisions of Alabama and federal law 

pertaining to the scope and limits of discovery, the attorneys for the parties to this lawsuit may 

request an interview with any healthcare providers, health plan administrators, or other 

individuals in connection with the aforesaid mentioned health information and payments thereof 

(such information collectively referred to hereafter as “protected health information”). Such 

healthcare provider, health plan administrator, or other individual may grant or deny a request for 

an interview. 

Case 3:06-cv-00645-MEF-TFM Document 6-2 Filed 09/26/2006 Page 1 of 3
This Court authorizes any third-party who is provided with a subpoena requesting 

the production of documents or commanding attendance at deposition or trial to disclose 

Protect Health Information in response to such request or subpoena. This Court Order is 

intended to authorize such disclosures under Section 164.512(e)(1) of the privacy 

regulations issued pursuant to the Health Insurance Portability and Accountability Act of

1996 (HIPAA). 

Nothing in this Order shall be deemed to relieve any party or attorney of the requirements 

of the Federal Rules of Civil Procedure. Nothing in this Order permits disclosure of confidential 

communications, made for the purposes of diagnosis or treatment of a patient’s mental or 

emotional condition, including alcohol or drug addiction, among the patient, the patient’s 

psychotherapist, including members of the patient’s family. Nothing in this Order permits

disclosure of records or information relating to HIV testing or sexually transmitted disease. 

Nothing in this Order shall be constructed to authorize any party or any attorney for any 

party to release, exchange, submit, or share any Protected Health Information with any other 

person or any other entity, other than an agent or employee of the attorney or party. This Order 

prohibits the parties from using or disclosing the Protected Health Information for any purpose 

other than this litigation or proceedings. 

At the conclusion of this action and at the written request of an Individual whose 

Protected Health Information has been disclosed, or such Individual’s authorized representative,

all recipients of the Protected Health Information shall return to the requesting party the 

documents and all copies thereof containing Protected Health Information received by them 

pursuant to this Order, except that Protected Health Information, which is included in insurance 

claim files and law firm litigation files, may be retained to allow compliance to the extent and for

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Case 3:06-cv-00645-MEF-TFM Document 6-2 Filed 09/26/2006 Page 2 of 3
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the period that such retention is required by Alabama insurance laws and the Alabama State Bar 

rules and regulations. 

 DONE and ORDERED this_____ day of____________________, 2006. 

 ______________________________________ 

 MARK E. FULLER 

 CHIEF UNITED STATES DISTRICT JUDGE 

cc: 

Michael S. Jackson 

Ryan Wesley Shaw 

Beers, Anderson, Jackson, Patty & Van Heest, P.C. 

P.O. Box 1988 

Montgomery, AL 36102-1988 

Case 3:06-cv-00645-MEF-TFM Document 6-2 Filed 09/26/2006 Page 3 of 3