Vickers v. U P Employees Federal Credit Union
PROTECTIVE ORDER. Signed by Judge D. P. Marshall Jr. on 12/17/12. (kpr)
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
U.P. EMPLOYEES FEDERAL CREDIT UNION
The parties have proposed an agreed protective order, which the Court
adopts with minor changes.
1. Confidential information, as defined by this Order, shall be used only
for the purpose of this litigation and no other purpose, and shall not be given,
shown, made available, or communicated in any way to anyone except
qualified persons, as defined by this Order.
2. Confidential information includes, but is not limited to:
(a) Documents containing confidential personal information such
as social security numbers, contact information, medical information,
dates of birth, information requested by a party, and other information
that may be deemed by this Court to be relevant or material.
(b) Any information of the type set forth in 2(a) as may be, from
time to time, produced by a party and declared by the party to be
"confidential information" and subject to this Order. Materials that are
designated as confidential and do not fall into one of the categories
named in Section 2(a), should be stamped confidential, or if Bates
numbers are used, may be designated as confidential by Bates number
in a letter. A party may oppose a confidentiality designation in writing
within ten days of the designation, at which time the parties shall
engage in a good faith effort to resolve the issue, and may move to
remove the confidentiality designation if that fails.
3. Except with the prior written consent of the defendant, or pursuant
to further Order of this Court on motion with notice to the Defendant, no
confidential information may be disclosed to any person other than" qualified
persons," defined to include the plaintiff, any future counsel for the plaintiff,
secretaries, para-professional assistants, experts, other employees of counsel
who would be assisting counsel with this action, court personnel, witnesses
at trial or deposition, and the jury.
4. Upon delivery of confidential information to the plaintiff's counsel,
the defendant or his counsel shall execute and submit to the plaintiff's counsel
a document entitled "inventory of confidential documents delivered" as
demonstrated in Exhibit 1. Documents containing confidential information
shall be stamped or otherwise marked as confidential.
5. This Order is binding through and after the conclusion of this
litigation. Three years after the conclusion of this action, including all
(a) Plaintiff and his 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 disci osing
in any manner any confidential information obtained during the course
of this proceeding. Severe sanctions will attach to any person who
discloses information in violation of this provision.
Nothing in this Order shall prevent any party from seeking
modification of this Order at any time as to specific matters designated
confidential information to remove those matters from the application of this
7. Documents that are entirely confidential and must be filed with the
Court shall be filed under seal.
Documents containing confidential
information may be filed in a redacted form so that those portions of the
document containing confidential information will not be visible to the public.
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.
D.P. Marsnall Jr.
United States District Judge
INVENTORY OF CONFIDENTIAL POCUMENTS PR,OVIDE:P
I hereby submit the following documents, document pages, and/or depositions which
are subject to the Protective Order for the protection of documents in Shantwan Vickers v.
U.P. Employees Fedel·al C:~:edit Union, filed in The United States Disb.'ict Court for the
Easteru District of A1·kansas, Western Division, Case No. 4:12-CV-00429-DPM.
:List all docum.eo.ts, pages, and depositions submitted below:
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