Ledgerwood et al v. Gillespie

Filing 41

AGREED PROTECTIVE ORDER. Signed by Judge D. P. Marshall Jr. on 9/23/2016. (jak)

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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS ETHEL JACOBS vs. PLAINTIFF NO. 3:16-CV-119 CINDY GILLESPIE, in her official capacity as Director, Arkansas Department of Human Services DEFENDANT AGREED PROTECTIVE ORDER THIS MATTER came on upon the stipulation of the parties that a Protective Order be entered pursuant to Federal Rule of Civil Procedure 26, governing the disclosure and use of certain info1mation to be provided by Defendant to Plaintiff during the discovery process. Disclosure and discovery activity may involve production of certain confidential information or private information for which special protection from public disclosure and from use for any purpose other this in this litigation is warranted. Accordingly, the parties hereby stipulate to this protective order as follows: l. That all Plans of Care and all Assessment Summary Reports, including redacted and deidentified Plans of Care and redacted and deidentified Assessment Summary Reports, provided to Plaintiff by Defendant in response to Plaintiffs discovery requests, including Plaintiffs Requests for the Production of Documents Nos. 12 through 21, except those of Plaintiff, Ethel Jacobs, be used only for purposes of this litigation and any appeals therefrom, if any, and not for any other purposes and not otherwise be disclosed or redisclosed to any person or entity other than: ( l) the parties to the litigation; (2) the Court and Court staff; (3) expert witnesses in this litigation Page 1of4 (4) court reporters; and (5) and counsel of record and their staff, including outside counsel, if any. The covered documents may be redisclosed to representatives of Defendant, including DHS counsel, officials, witnesses and representatives. 2. These Plans of Care and Assessment Summary Reports, including de-identified Plans of Care and Assessment Summaries and Reports provided to Plaintiff by Defendant, may possibly contain confidential informational or private information even after deidentification. 3. All Plans of Care and Assessment Summary Reports will be stored and maintained by Plaintiff, through counsel, at a location and in a secure manner that ensures that access is limited to those allowed under this Order until either destroyed and returned to Defendant's counsel after completion of litigation. 4. The Court will retain jurisdiction for one year after the end of the case (including appeals) to enforce this order. Thereafter, the parties' obligations will be solely a matter of contract. PURSUANT TO THIS STIPULATION, IT IS SO ORDERED. D. P. Marshal(Jr. United States District Judge Page 2 of 4 AGREED: Date: Kevin De Llban, AR Bar No. 2012 Legal Aid of Arkansas 310 Mid-Continent Plaz.a., Suite 420 West Memphis, AR 72301 800/ 967-9224 kdeliban@arlegalaid.org Counsel for Plaintiff AGREED: Date: 9. J2 7-/ I \e Am~058 Legal Aid of Arkansas 7 I 4 S. Main Street Jonesboro, AR 7240 I 800/ 967-9224 apritchard@arlegalaid.org Counsel for Plaintiff AGREED: david.sterling@dhs.arkansas.gov Counsel for Defendant Page 3 of 4 AGREED: Date --'J/l!/1~--- ---··-· - 3l~~~7~ ·· Richard Rosen, AR:"J:i~rN~.97164-· Office of Chief Counsel P.O. Box 1437, Slot S260 Little Rock, AR 72203 501/320-6334 rich.rosen@dhs.arkansas.gov Counsel for Defendant Page 4 of 4

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