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)

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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 1 192321 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 3 192321 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 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: 501-315-1910 Facsimile: 501-315-1916 Email: luthersutter@yahoo.com and Bryan R. Huffman Spears Huffman, PLLC 113 South Market Street Benton, AR 72015 Telephone: 501-315-0092 E-mail: bhuffman@spearshuffman.com 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: 501-688-8810 Facsimile: 501-918-7810 bfreeland@mwlaw.com ATTORNEYS FOR SEPARATE DEFENDANT SHERWOOD URGENT CARE, INC. 4 192321 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: _ _ _ _ _ __ 5 192321

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