Cox v. Capital Quarries Company Inc
JOINT STIPULATION AND PROTECTIVE ORDER. Signed by Judge J. Leon Holmes on 6/18/2014. (jak)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF ARKANSAS
PATRICIA D. COX
Case No.: 3:13-CV-00195
CAPITAL QUARRIES COMPANY, INC.
PARTIES' .JOINT STIPULATION AND PROTECTIVE
ORDER REGARDING CONFIDENTIALITY
The Parties to this action, Plaintiff Patricia Cox ("Plaintiff' or "Cox") and Defendant
Capital Quarries Company, Inc., ("Defendant"), have stipulated, through their respective
counsel, to the entry of this Protective Order Regarding Confidentiality ("Protective Order").
During the course of the litigation of this matter, Plaintiff and Defendant may identify
and agree to produce certain documents containing confidential and personal information
pertaining to the parties as well as individuals who are not parties to this action.
The purpose of this Protective Order is to ensure that the said documents are restricted to
persons involved with the litigation of this matter. Specifically, Plaintiff may identify and agree
to produce, her own medical and financial records. Defendant may identify and agree
produce personnel records of third parties.
Accordingly, the documents and information
identified in this Paragraph are subject to the provisions of this Protective Order.
Moreover, during the course of discovery, the Parties may request additional personal,
confidential, or proprietary documentation from each other or from third parties. If any
documents which will be produced contain personal, confidential, or proprietary information, the
producing Party (including any third party producing such documents) may mark the documents
"CONFIDENTIAL." Any document so marked shall not be disclosed to any person except as
may be permitted by this Protective Order. The designation of any document as
"CONFIDENTIAL" will be made in good faith, and the Parties shall have ten (10) days after
service of documents marked "CONFIDENTIAL" to challenge such designation by filing a
motion with the Court.
In the event that personal, confidential or proprietary information is disclosed in response
to an interrogatory, the answering party may designate the response as confidential information
by conspicuously stamping the interrogatory answer with the word "CONFIDENTIAL." Parties
to this action may also designate deposition testimony that reveals personal, confidential or
proprietary information as confidential by advising all persons present that the party believes that
the portion of the deposition in question falls under the scope of this Joint Stipulation Order.
The parties will redact confidential information from any documents produced in the
course of this litigation pursuant to the Rule 5.2 of the Fed. R. Civ. P. However, they reserve the
right to file a motion to produce with the Court should same become relevant to the litigation of
The use of any documents or information therein subject to this Protective Order shall be
restricted to the following persons:
The Parties to this litigation;
Counsel for the Parties, including their respective paralegals and clerical
Witnesses or prospective witnesses, including but not limited to persons requested
by counsel to furnish technical or other expert service, to give testimony or to otherwise prepare
for any deposition, hearing, trial, or any other proceeding in this action, provided such witness or
prospective witness agrees to be expressly bound by the terms of this Protective Order and not
disclose the documents or information therein to any party or person outside this litigation; and
The Court and its personnel, including the stenographic reporters not regularly
employed by the Court who are engaged by the Parties or the Court during the litigation of this
Upon final termination of this action, whether via completion of the litigation process,
trial and any appeal in this action and the satisfaction of any judgment, or upon the conclusion of
settlement of this action, all persons subject to this Order shall return to the producing Party,
upon request, all documents and information subject to this Protective Order, including any and
all copies, prints, negatives, or summaries, in the possession of employees, experts, or
consultants employed or retained by counsel for the Parties, except those items compromising
any appellate record, hearing record, deposition, trial court record, privileged communications, or
attorney work product.
Whenever any documents marked as "CONFIDENTIAL" are entered into the record,
such documents shall be filed under seal, except when such documents are used at trial.
No Party shall seek sanctions based on an application to the Court for an interpretation of
confidentiality pursuant to this Protective Order. Each Party shall bear its own attorney's fees
related to any such application.
so ORDERED THIS I g~
DAY OF _ _
United States District Court Judge
Patricia Cox, Plaintiff
Larry J. Steele, Attorney at Law
115 Abby Road
P.O. Box 561
Walnut Ridge, Arkansas 72476
Telephone : (870) 886-5840
Facsimile: (870) 886-5873
BY: /s/ Larry J. Steele
Larry J. Steele
Arkansas Bar No. 78146
Capital Quarries Company, Inc., Defendant
Michael S. Moore, Attorney at Law
FRIDAY, ELDREDGE & CLARK, LLP
400 West Capitol Avenue
Little Rock, Arkansas 2201-3493
Telephone: (501) 370-1526
Facsimile: (501) 244-5348
Michael S. Moore
Arkansas Bar No. 82112
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