Wright v. Sherwood Urgent Care Inc et al
PROTECTIVE ORDER pursuant to Stipulation and Agreement. Signed by Judge James M. Moody on 4/30/12. (kpr)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF ARKANSAS
NO. 4:11CV"()529 JMM
SHERWOOD URGENT CARE, INC.;
WEATHERFORD ARTIFICIAL LIFT SYSTEMS,
INC.; WEATHERFORD INTERNATIONAL OIL
FIELD SERVICES, LTD; AND JOHN DOE 1
PROTECTIVE ORDER PURSUANT TO STIPULATION
day of April. 2012. the Court reviewed the stipulation and
agreement for a Protective Order between the Plaintiff and Defendants, and makes the following
Confidential Information. as later defined herein, and produced by either party or
pursuant to a release for medical or employment records in this action. shall be used only for
the purpose of this litigation and for no other purpose whatsoever, and shall nof be given,
shoWn. made available. or communicated in any way to anyone except Qualified Persons. as
Confidential Information shall be deemed to include. without limitation:
Those personnel files. staffing information, board minutes and records,
descriptions, rates of pay, poliCies, training materials, insurance coverage
benefits information. financial
information, trade secrets, and other matters now requested or
hereinafter requested by the parties or relating to the operation and
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
At the conclusion of this action, including all appeals:
At the end of three (3) years following the conclusion of this case, counsel
may destroy the confidential information or, prior to the expiration of the
three (3) year deadline, counsel may take all reasonable steps necessary
reclaim all Confidential
memoranda. notes, or any other documents embodying such Information,
in whole or in part, by requesting the return of all copies of such
Confidential Information and paying reasonable expenses for the return of
Counsel and all Qualified Persons are enjoined from disclosing in any
manner any Confidential Information obtained during the course of this
Nothing in this Order shall prevent any party from seeking modification of this
Order at any time as to speclfic matters designated "Confidential Information" to remove such
from the application of this Order.
Such Confidential Information 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 proceeding until further
Order of this Court.
IT IS HEREBY SO ORDERED.
ONORABlE JAMES MOODY
DISTRICT COURT JUDGE
APPROVED AS TO FORM:
CROSS. GUNTER, WITHERSPOON & GALCHUS. P.C.
Carolyn B. Witherspoon (AR Bar # 78172)
Gregory J. Northen (#2011181)
500 President Clinton Ave .• Suite 200
Little Rock. Arkansas 72201
Telephone: (501) 371-9999
Facsimile: (501) 371-0035
151 Gregory J. Northen
Gregory J. Northen
Attorneys for Separate Defendant,
Weatherford Artificial Lift Systems, Inc.
Luther One I utter (#95031)
Sutter & Gillham. PLLC
Post Office Box 2012
Benton. AR 72018
Bryan R. Huffman
Spears Huffman, PLLC
113 South Market Street
Benton, AR 72015
A TTORNEYS FOR PLAINTIFF GREG WRIGHT
lsi Byron Freeland
Byron Freeland, Ark. Bar No. 72039
Mitchell. Selig. Williams.
Gates, & Woodyard, P.L.L.C.
425 West Capitol Avenue. Suite 1800
Little Rock. Arkansas 72201
ATTORNEYS FOR SEPARATE DEFENDANT
SHERWOOD URGENT CARE, INC.
INVENTORY OF CONFIDENTIAL DOCUMENTS RECEIVED
I hereby acknowledge receipt of the following documents, document pages, and/or
depositions which are subject to the Protective Order for the protection of documents in GREG
WRIGHT V. SHERWOOD URGENT CARE, INC.; WEATHERFORD ARTIFICIAL LIFT
SYSTEMS, INC.; WEATHERFORD INTERNATIONAL OIL FIELD SERVICES, LTD; and
JOHN DOE 1; CASE NO.: 4:11CV-529 JMM (list all documents. pages, and deposiUons
DATE: _ _ _ _ _ __
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