Brantley v. UPS Ground Freight Inc et al
Filing
103
PROTECTIVE ORDER. Signed by Judge D. P. Marshall Jr. on 2/21/2018. (jak)
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
JONESBORO DIVISION
KIMBERLY D. BRANTLEY,
ADMINISTRATRIX OF THE ESTATE
OF BENJAMIN BRANTLEY,
DECEASED
Plaintiff
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vs.
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UPS GROUND FREIGHT, INC.;
OPTIMUM STAFFING, INC. d/b/a
OPTIMUM LOGISTIC SOLUTIONS;
ROBERT L. WOODALL and
JOHN DOES 1-6
Civil Action No. 3: 16-CV-352DPM
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Defendants
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PROTECTIVE ORDER
With the parties' agreement, and pursuant to Federal Rule of Civil Procedure
26(c), the Court orders:
1. Defendants Optimum Staffing, Inc. and Robert L. Woodall ("Defendants")
served The Second Set of Interrogatories and Requests for Production of
Documents upon Jimmy "Ronnie" Brantley, Kimberley Brantley, Danielle
Brantley, and Kaylin Brantley, which includes interrogatories regarding
healthcare
history and
a
request
for
production
for
a
medical
authorization.
2. Jimmy "Ronnie" Brantley, Kimberley Brantley, Danielle Brantley, and
Kaylin Brantley have objected to the Second Set of Interrogatories and
Requests for Production of Documents.
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3. Counsel have conferred in good faith and in order to avoid the need for a
motion, the parties, by and through their undersigned attorneys of record,
hereby stipulate and agree as stated herein.
4. Jimmy "Ronnie" Brantley, Kimberley Brantley, Danielle Brantley, and
Kaylin Brantley will provide supplemental responses, including providing
their medical care history and the authorization presented by Defendants.
Jimmy "Ronnie" Brantley, Kimberley Brantley, Danielle Brantley, and
Kaylin Brantley reserve all objections as to the admissibility of these
records or history.
5. Defendants will produce all records obtained from this authorization to
counsel for Jimmy "Ronnie" Brantley, Kimberley Brantley, Danielle
Brantley, Kaylin Brantley and UPS.
6. Defendants will deem the records obtained from the medical authorization
as CONFIDENTIAL INFORMATION-SUBJECT TO PROTECTIVE ORDER
and will maintain the records in a safe and secure manner and will treat
the records obtained from the medical authorization as ATTORNEY EYES
ONLY, meaning that the records will be seen only by counsel and counsel's
staff at their respective law offices. The CONFIDENTIAL INFORMATION
shall not be used or disclosed for any purpose other than the preparation
and trial of this case and in any appeal taken from any judgment herein.
7. Defendants will disclose to Plaintiffs counsel by reference to Bates Label
Number any record they believe are admissible in this litigation. If after a
good faith conferral with counsel, Jimmy "Ronnie" Brantley, Kimberley
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Brantley, Danielle Brantley, and Kaylin Brantley continue to object to the
admissibility of the record identified by Defendants, then the parties must
attempt in good faith to resolve the issue. If the parties can't resolve the
dispute, they must file a joint report pursuant to the Final Scheduling
Order, Ng 97 at 3.
8. CONFIDENTIAL INFORMATION will not be filed on the public docket. If
practicable, it shall be redacted.
FED. R. C1v. P. 5.2.
If redaction 1s
impracticable, a party must move for permission to file under seal any
confidential information and related motion, brief, or paper containing that
material. The moving party must justify its sealing with specifics and solid
reasons, including an explanation about why redaction cannot be done.
9. Defendants will return all CONFIDENTIAL INFORMATION to Plaintiffs
counsel (unless ruled admissible by this Court) within 45 days of the
conclusion of this litigation.
This Court hereby retains and shall have
continuing jurisdiction for one year over each and every person who
receives copies of Confidential Documents, Materials or other Information
hereunder for enforcement of the provisions of this Order following
Consent to the continuing personal
termination of this litigation.
jurisdiction of this Court for enforcement of this Order shall be deemed
given by any person receiving confidential documents or information
hereunder. This continuing jurisdiction shall expire one year after this
case ends, including any appeal. Thereafter, the obligations imposed shall
be solely a matter of contract between the parties.
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IT IS SO ORDERED on this ;2.i?t day of _ _.1-e--=fuCL...:....:..lvM.,._,,_,Y'----' 2018.
I
D.P. Marshall Jr.
()
United States District Judge
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