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Tri-State Armature & Electrical Works Inc. v. Houston

United States District Court, E.D. Arkansas, Jonesboro Division

January 3, 2017

TRI-STATE ARMATURE & ELECTRICAL WORKS, INC., Plaintiff,
v.
TIMOTHY B. HOUSTON, ELECTRO DESIGN ENGINEERING, INC., and CELETA STRIPLING, Defendants.

          JAMES M. SIMPSON, ESQ., SHAWN R. LILLIE, ESQ. Attorneys for Plaintiff Tri-State Armature & Electrical Works, Inc.

          MICHAEL E. MULLALLY, ESQ. Snellgrove, Langley, Culpepper, Williams & Mullally Attorneys for Defendant Timothy B. Houston

          JEFFREY W. PURYEAR, ESQ., ARIEL J. SNYDER, ESQ. Womack, Phelps, Puryear, Mayfield & McNeil, PA. Attorneys for Defendants Electro Design Engineering, Inc. and Celeta Stripling

          AGREED PROTECTIVE ORDER

          D.P. MARSHALL JR. U.S. DISTRICT COURT JUDGE

         In order to protect and preserve the confidentiality of information obtained by the parties in connection with this case, the Court, with the consent of the parties, hereby orders as follows:

         A. Scope of Application

         1. This protective order shall govern all testimony, information, documents and other information and materials generated or produced in response to any discovery conducted by any party to the litigation pursuant to the Federal Rules of Civil Procedure.

         2. Except as otherwise provided herein, nothing contained in this Order shall impose any restrictions on the use or disclosure of documents or information obtained independent of the formal discovery proceedings in this litigation.

         3. A party may designate information disclosed during a deposition or in response to written discovery as "Confidential/Attorney's Eyes Only" by so indicating in those responses or on the record at the deposition and requesting the preparation of a separate transcript of such material. This designation shall mean that, in addition to the limitations on disclosure set forth in Section C, disclosure will not be made to the party, its employees, or in-house counsel. Except as otherwise provided below, each page of discovery material so designated must be stamped with the legend "Confidential/Attorney's Eyes Only" by the producing party in a manner that will not render any portion of the document illegible. The designation shall also apply to any copies, excerpts or summaries of the designated information.

         B. Designation of Documents or Other Materials

         1. Any party or non-party may designate as "Confidential" (by stamping the relevant page or taking steps specified in this Order) any document or information provided in response to discovery which that party or non-party considers in good faith to contain non-public, confidential, trade secret or proprietary information.

         2. A party or non-party may designate information disclosed during a deposition or in response to written discovery as "Confidential" by so indicating in those responses or on the record at the deposition and requesting the preparation of a separate transcript of this material. Additionally, a party or non-party may designate in writing, within thirty days after the court reporter's mailing of the deposition transcript for which the designation is proposed, the specific pages of the transcript to be treated as "Confidential." To ensure this designation, deposition transcripts shall be treated "Confidential" for thirty days after mailing by the court reporter. Except as otherwise provided below, each page of discovery material so designated must be stamped with the legend "Confidential" by the producing party in a manner that will not render any portion of the document illegible. The designation shall also apply to any copies, excerpts or summaries of the designated information.

         3. Any other party may object to a designation of "Confidential" or "Confidential/Attorney's Eyes Only." If an objection is entered, the objecting party shall follow the procedures described in Section F below. After any confidential designation is made according to this Order, the designated documents or information shall be treated "Confidential" until the matter is resolved according to the procedures described in Section F below.

         4. This Order shall apply equally to any and all documents and information produced or provided prior to the date of this Order, and each party shall have thirty days from the date of this Order to notify the other party in writing as to which previously produced ...


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