Scott v. Redus et al

Filing 33

AGREED PROTECTIVE ORDER. Signed by Judge James M. Moody on 4/13/11. (kpr)

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FILED u.s. DISTRICT COURT EASTERN DISTRICT ARKANSAS IN THE UMfEJ) STATES DISTRICf COURT FOR THE EASTERN DISTRICf OF' ARKANSAS PINE BLUFF DIVISION APR 13 2011 JAM By:~,..,..~s...tiiI...u:;~=-=-=-_ DEPCLERK WALTER SCOlT, JR. PLAINTIFF v. CASE NO. 5:1o..CV...{)138 JMM MAYOR CARL A. REDUS, In His Official Capacity As Mayor for the CIty of Pine Blair; CITY OF PINE BLvnr,· A Manlcipal Corporation and Public Body Corporate and PolitiC; BRENDA DA~ONES, 10 Ber Oftlclal Capacity as ChlefofPoUee, Pine Blutt Pol~ Department; JOHN HOWELL, In His Individual And Otr'ldal Capacity as former Chief of Police, Pine BlofT Pollee Department; AHMAD PACE, In His Individual and Offidal Capacity as a Police Officer for the City of Pine Bluff, Arkansas; PJ'S DISCO PRIVATE CLUB DEFENDANTS AGREED PROTECfIVE ORDER Plaintiff has requested discovery of records contahting sensitivepersoo8J information. In order to pennit Plaintiff adequate access to the records necessary to completely present this case . herein, and, at the same time to address priVIW)' concerns, it is hereby ORDERED, ADJUDGED and DECREED as follows: l. AInn~ Plaintiff has made discovery requests fur copies of the persoone] files upon Pace (personal infonnatioD sucb as addresses and social security nwnbers win be redacted). In addition, Plaintiff has requested aU complaints and internal affidrs docwnents regarding Ahmad Pace. The parties have agreed that due to the private and sensitive nature of these documents. a protective oroer should be entered before these documents are provided to Plaintiff. 1 2. Any docwncnts produced in response to discovery requests as provided in Paragraph I above shall be considered confidential; 3. AU confidential records or other infonnation provided hereunder shall be used for the purpose of this litigation and none of the confidential material may be used for any other purpose whatsoever without a new request for the material. Moreover. neither Plaintift; Defendants, or their counsel may utilize directly or indirectly the confidential records, documents, or other information made available pursuant to this Order in any other administrative complaint, proceeding, or civil action without a new request; 4. All confidential reco~ docwnents, tapes, or other infonnation provided heceunder shall be retained in the custody of the Plaintitrs or Defendants' counsel including their paralegal, sec:retarial staff. andlor other staff members. during the pendency of this litigation. Plaintiff's and Defimdants' counsel may also provide copies of such confidential records, documents or other information to any expert wimcss[es] retained by the Plaintiff or Defendant or persons frequently employed by such expert(s] whose review of the material is necessary for the Plaintiff's and Defendants· prosecution in 1his litigation; 5. If .confidential documents or records are used during depositions, the depositions shall be treated as confidential in accordance with this Order; 6. Any document. information or deposition designated as confidential under this Order shall. when filed with the Court, be clearly maIked confidential, scaled, placed in separate, secure storage by the Clerk, and opened only by authorized Court personnel; 7. Plaintiff. Defendants, their respective counsel and their staff and the retained expert witnesslwitnesses shall not in any mumer. directly transfer confidential records. 2 documents or other information provided hereunder or copies thereof, or communicate. orally or in writing, any ofthe data contained in said material to any person; 8. Plaintifi's counsel, and Defendants' counsel promptly upon completion of this litigation, or before if at such time they have no further use of the confidential infonnation. whichever shall first occur, shall return to the Defendant and Plaintiff all materials produced, and aU copies and extracts of data from such materials; 9. This Protective Order shall govern all pre-trial proceedings. but shall be subject to modification either before, during or aftec the trial on the merits, upon application of any of the parties to this lawsuit and for good cause shown; 10. The provisions of this Order shall not affect the admissibility ofevidence at trial or any preliminary evidentiary proceeding in open court, except as directed by separate Order oftbis Court; and 11. This Order is without prejudice to the rights ofany party to make objections to the discovery as permitted by the Arkansas Rules of Civil Procedure, or by any statute or other authority. IT IS SO ORDERED TIllS \~ DAYOF~ norable Iames M. Moody United States District Court By: yM. Attorney r P.O. Box North Little Rock, AR 72115 TELEPHONE: 501-978-6117 FACS~:SOl-537-7267 BMAlL: 3 ,2011. And By: w ~0'1(). °&QaJ Willard Proctor. Jr. Attomey ror Plaintiff 2100 Wolfe Street Little Rock, AR 72202-6258 TELEPHONE: 501-374-9156 FAJ(:501-325-4959 EMAD..: wprocto(ir@aol.CQgl And By: ..,....-------­ M. Keith Wren and Associates Attomey for John Howell 942) W. Marlcham St.• Suite B Little Rock, ArlaInsas. 72205 Telephone No. 501-223-9736 Fax No. 501-228-8887 Email: And BY:-« C-~~. Taylor (rAJ C:~c..~J\., Attome)Sfor PI's Disco &; Night Club Brockman. Norton &. Taylor 501 East Eighth Avenue Post Office Box 8967 Pine Bluff, AR 71611-8967 Telephone: 87Q-S34-2SSt FAX: 870-534-1696 Email: bntlawfinn@gmai1.00m, 4 And By: _ Willard Proctor, Jr. Attorney for Plaintiff 2100 Wolfe Street Little Rock, AR 72202-6258 TELEPHONE: 501-374-9156 FAX: 501·325-4959 EMAIL: And By: m~ M. Keith Wren and Associates Attorney for John Howell 9421 W. Markham St., Suite B Little Rock, Arkansas, 72205 Telephone No. 501-223-9736 Fax No. 501-228-8887 Email: And By: _ Zachary Taylor Attorney for PJ's Disco & Night Club Brockman, Norton & Taylor 501 East Eighth Avenue Post Office Box 8967 Pine Bluff, AR 7161 1-8967 Telephone: 870-534-2551 FAX: 870-534-1696 Email: bntlawtirm(a) 4

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