Rodriguez et al v. King of Fans Inc
STIPULATED PROTECTIVE ORDER. Signed by Judge D. P. Marshall Jr. on 11/30/11. (kpr)
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
FERNANDO and DONNA RODRIGUEZ
NO. 4:11 CV-498 DPM
KING OF FANS, INC.
STIPULATED PROTECTIVE ORDER
Except as otherwise ordered by the Court, this Order shall apply to all documents
and items supplied by KING OF FANS, INC. in this case which are designated as "confidential"
or "subject to Protective Order" or similar designation.
"Confidential Information" shall be deemed to include, without limitation, any
documents, written discovery responses, or deposition testimony that a Party or its counsel
designates as confidential based upon a good faith belief that the designation is appropriate
because either documents, written discovery responses, or deposition testimony contain
proprietary or confidential business or financial information, trade secrets, or non-public
information of a commercially sensitive, personal or private nature, as mandated and governed by
Rule 26 [c]  of the Federal Rules of Civil Procedure.
A Party or its counsel must designate in writing information as Confidential
Information. Such designation may be by letter.
Information revealed or contained in a deposition which is confidential pursuant
to this Order shall be identified in the deposition as being confidential and subject to this Order.
That portion of the deposition shall thereafter be separately reflected as confidential and
being subject to this Protective Order.
Except with prior written consent of counsel of KING OF FANS, INC. or prior
order of the Court, confidential information subject to this Protective Order shall only be
disclosed as follows: (a) to counsel of record for the respective parties including their office and
clerical staff; (b) officers, directors and necessary employees of any party in connection with the
trial preparation of that party in this case; (c) expert witnesses or consultants engaged by a party
to assist in the prosecution or defense of the action provided such witnesses and consultants
separately agree to be bound and governed by the terms of this Order; (d) the Court and Court
personnel subject to such safeguards as the Court may deem necessary; (e) non,party witnesses
and their counsel only to the extent disclosure is necessary for their testimony and provided that
they shall separately agree to be bound and governed by the terms of this Order.
All parties and persons to whom confidential information and/or documents are
disclosed are authorized only to use such information and documents in connection with this
action and are precluded from disclosing the information or documents to any other person
except as specifically provided herein.
No person receiving or reviewing such confidential
information shaH disclose it or its contents to any person other than those authorized by this
Order and for the purposes specified in this Order.
At the conclusion of this litigation, the parties and their counsel shall, upon
request, return to counsel for KING OF FANS, INC. all documents and items which are
confidential and supplied subject to this Order as well as any copy, notes, or record of
confidential information supplied by KING OF FANS, INC. subject to this Order including
copies supplied to experts, consultants, or witnesses.
If any party disputes the designation by KING OF FANS, INC. of any particular
document or information as confidential and subject to this Protective Order then, in that event,
the parties so disputing the designation may apply to the Court for a determination as to whether
that particular document or information should be subject to this Protective Order.
The provisions of this Order shall survive and remain in force and effect after the
conclusion of this litigation whether the conclusion be by settlement or litigation. The Court
retains jurisdiction to construe and enforce the provisions of this Order.
The treatment of
confidential information to be introduced at trial shall be the subject of a later Order as will be
determined by the Court at a later date.
IT IS SO ORDERED.
APPROVED AND AGREED TO:
MITCHELL LAW FIRM
Attorneys for Plaintiffs
425 West Capitol Avenue, Ste. 1800
Little Rock, AR }}201c:;/
?Zachary T. Steadman
BARBER, McCASKILL, JONES & HALE, P.A.
Attorneys for Deftndant
2700 Regions Center
400 West Capitol Avenue
Little Rock, AR 72201-3414
(501) 372- 75
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