Bone v. G4S Youth Services LLC et al

Filing 35

PROTECTIVE ORDER. Signed by Judge Brian S. Miller on 3/15/11. (kpr)

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Bone v. G4S Youth Services LLC et al Doc. 35 IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS WESTERN DMSION TONI BONE PLAINTIFF CASE NO. 4:09-CV-00685BSM v. G4S YOUTH SERVICES, LLC, MARY STEELE in her individual & official capacity, VALENCIA PUMPHR;EY in her individual & official capacity, ARKANSAS DEPARTMENT OF HUMAN SERVICES, and TODD SPEIGHT On this, the l ~ day of DEFENDANTS ~ (" ~ l 2011, the Court reviewed the stipulation and agreement for a Protective Order, and makes the following Orders: 1. Confidential Infonnation, as later defined herein, and obtained by the Plaintiff from the Defendant in this action, shall be used only for the purpose of this litigation and for no other purpose whatsoever, and shall not be given, shown, made available or communicate in any way to anyone except Qualified Persons, as herein defmed. 2. Confidential Jnfonnation shall be deemed to include, without limitation: (a) Those policies of the company, timesheets, sign-in sheets, personnel files (including, but not limited to social security numbers, dates of birth, medical and financial infonnation), salary history, and information and other matters now requested or hereinafter requested by the Plaintiff, from the Defendant relating to the operation organization ofthe Defendant and such other information as may be deemed by this court to be relevant or material herein. (b) Any information concerning such as set forth in 2(a) herein as may be, from time to time, produced by the Defendant to the Plaintiff herein and declared by the Defendant at the time of production to be "Confidential fufonnation" and subject to this Order, such designation to be in writing and may be by letter of transmittal to the Plaintiff. 3. Except with the prior written consent of the Defendant, or pursuant to further Order of this Court 011 motion with notice to the Defendant, confidentiallnfonnation maybe disclosed to any person other than "Qualified Persons" who shall be defined to include the Plaintiff, any future counsel of record for the Plaintiff in this action, and secretaries, paraprofessional assistance, experts and other employees of such counsel will 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 Confidential fufonnation to be Plainti:frs counsel herein, the Defendant (or Defendants' counsel) shall execute and submit to Plaintiff's counsel a document entitled "Inventory of Confidential Documents Delivered" in the form affIxed hereto as Exhibit 1. 5. This Order, insofar as it restricts the communication in any way and use of Confidential Information, shall continue to be binding through and after the conclusion of this litigation. Three years following the conclusion ofthis action, including all appeals: (a) Plaintiff and Plaintiff's counsel shall destroy all confidential information, including, correspondence, memoranda, notes or any other documents embodying such information, in whole or in part. (b) Counsel and all Qualified Persons are enjoined from disclosing in any manner and Confidential Information obtained during the course ofthis proceeding. 2 Severe sanctions will attach to any person who discloses such in violation of this provision. 6. Nothing in this Order shall prevent any party from seeking modification of this Order at any time as to specific matters designated "Confidential fufonnation" to remove from the application of this Order. 7. Such Confidential as may be required to be filed with the Court and with the Clerk of this Court shall be filed under seal. Only the Court, Court personnel, and counsel for the parties shall have access to the sealed record in this record proceeding until further Order of this Court. IT IS HEREBY ORDERED. United States District Judge utien R. Gillham, Ark. Bar No. 99199 HARRILL & SUTTER, PLLC Attorneys at Law P.O. Box 2012 Benton, AR 72018 Attorneys for Plaintiff Toni Bone M. Eddings, Ark. Bar No. 2002008 ldredge & Clark LLP 2000 R ions Center est Capitol Avenue Little Rock, AR 72201 Attorney for Defendants G4S Youth Services and Todd Speight 3

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