Wright v. Sherwood Urgent Care Inc et al

Filing 28

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

WESTERN DIVISION

GREG WRIGHT

PLAINTIFF
NO. 4:11CV"()529 JMM

SHERWOOD URGENT CARE, INC.;

WEATHERFORD ARTIFICIAL LIFT SYSTEMS,

INC.; WEATHERFORD INTERNATIONAL OIL

FIELD SERVICES, LTD; AND JOHN DOE 1

DEFENDANTS

PROTECTIVE ORDER PURSUANT TO STIPULATION
AND AGREEMENT
On this

30

day of April. 2012. the Court reviewed the stipulation and

agreement for a Protective Order between the Plaintiff and Defendants, and makes the following
Orders:
1.

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
herein defined.
2.

Confidential Information shall be deemed to include. without limitation:
a)

Those personnel files. staffing information, board minutes and records,
handbooks,

by-laws,

medical

reports,

medical

information,

job

descriptions, rates of pay, poliCies, training materials, insurance coverage
information,

benefits information. financial

information.

proprietary

information, trade secrets, and other matters now requested or
hereinafter requested by the parties or relating to the operation and

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I.

q

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.

At the conclusion of this action, including all appeals:
a)

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
to

reclaim all Confidential

Information,

Including

correspondence.

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
the documents.

b}

Counsel and all Qualified Persons are enjoined from disclosing in any
manner any Confidential Information obtained during the course of this
proceeding.

6.

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.

7.

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.

a~lM~
ONORABlE JAMES MOODY
DISTRICT COURT JUDGE

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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: [phone]
Facsimile: [phone]
By:

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
Telephone: [phone]
Facsimile: 501-315-1916
Email: [e-mail]
and
Bryan R. Huffman
Spears Huffman, PLLC
113 South Market Street
Benton, AR 72015
Telephone: [phone]
E-mail: [e-mail]
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
Telephone: [phone]
Facsimile: 501-918-7810
[e-mail]
ATTORNEYS FOR SEPARATE DEFENDANT
SHERWOOD URGENT CARE, INC.
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EXHIBIT 1

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
received):

DATE: _ _ _ _ _ __

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