Stoner v. Arkansas Department of Correction et al

Filing 23

PROTECTIVE ORDER regarding confidential information. Signed by Judge Brian S. Miller on 11/18/11. (vjt)

Case 3:10-cv-00218-BSM Document 21-1

Filed 11/16/11 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF ARKANSAS
JONESBORO DIVISION
TRACY STONER
v.

PLAINTIFF
Case No. 3:10-CV-218 BSM

ARKANSAS DEPARTMENT OF
CORRECTION, et al.

DEFENDANTS

PROTECTIVE ORDER
The Department of Correction’s unopposed motion for a protective order,
Document No. 21, is granted. The parties stipulate and the Court orders:
1. Defendants John Maples and Arkansas Department of Correction have
requested information and documents in the present case from plaintiff Tracy
Stoner that plaintiff considers confidential. Specifically, defendants requested in
discovery copies of plaintiff’s state and federal income tax returns for the tax years
of 2009 through the date of trial. Plaintiff responded that it would produce these
records once an Order of Protection has been entered in this case.
2. Plaintiff is to produce these documents to defendants Maples and ADC,
as well as to defendant Corizon. These documents and the information contained
within them shall be used only for the purpose of this litigation and for no other
purpose. It shall not be given, shown, made available, or communicated in any
way to anyone except “Qualified Persons.”
3. Except with the prior written consent of plaintiff, or pursuant to further
order of this Court on motion with notice to plaintiff, these documents and the

Case 3:10-cv-00218-BSM Document 21-1

Filed 11/16/11 Page 2 of 4

information contained within them may be disclosed to any person other than
“Qualified Persons” who shall be defined to include defendants ADC/Maples and
Corizon, any future counsel of record for these defendants, as well as secretaries,
para-professional assistants, experts, and other employees of the parties who
would be actively engaged in assisting counsel in connection with this action,
court personnel, witnesses at trial or deposition, and the jury.
4. Upon delivery of these documents to defendants’ counsel, plaintiff’s
counsel shall execute and submit to the counsel for defendants a document entitled
“Inventory of Confidential Documents Delivered” in the form attached as Exhibit
1. These documents shall be identified by document number.
5. This Order shall continue to be binding through and after the conclusion
of this litigation. Three years following the conclusion of this action, including
appeals:
(a)

Defendants shall destroy these documents.

(b)

Counsel for defendants and all Qualified Persons are enjoined from

disclosing in any manner any of these documents or the information contained
within them obtained during the course of this proceeding.
6. Nothing in this Order shall prevent any party from seeking modification
of this Order.
7. If these documents or information contained within them are included in
any papers to be filed in court, they shall be redacted in accordance with Federal
Rules of Civil Procedure 5.2.
2

Case 3:10-cv-00218-BSM Document 21-1

SO ORDERED.

Filed 11/16/11 Page 3 of 4

November 18, 2011.

________________________________
HON. BRIAN S. MILLER
United States District Judge
/s/ Lucien Gillham
Counsel for plaintiff Tracy Stoner
/s/ Edward Hollis
Counsel for defendant Correctional
Medical Services (now Corizon)
/s/ Lori Freno
Counsel for defendants Arkansas
Department of Correction and John
Maples

3

Case 3:10-cv-00218-BSM Document 21-1

Filed 11/16/11 Page 4 of 4

EXHIBIT 1
INVENTORY OF CONFIDENTIAL DOCUMENTS PROVIDED
I hereby submit the following documents that are subject to the
Protective order for the protection of document in Stoner v. Arkansas
Dept. of Correction, et al., filed in the United States District Court for
the Eastern District of Arkansas, Jonesboro Division, Case No. 3:10CV-218 BSM (list all documents, pages, and depositions below):
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________________________________________________________
__________________

DATED: _________________

SIGNATURE: __________________

4