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Forrester v. Lafayette County

United States District Court, W.D. Arkansas, Texarkana Division

April 5, 2017

EARL FORRESTER PLAINTIFF
v.
LAFAYETTE COUNTY, ARKANSAS DEFENDANT

          ATCHLEY, RUSSELL, WALDROP & HLAVINKA, L.L.P. Louise Tausch Brandon Cogburn ATTORNEYS FOR PLAINTIFF, EARL FORRESTER.

          RAINWATER, HOLT & SEXTON, P.A. Thomas J. Diaz ATTORNEY FOR DEFENDANT, LAFAYETTE COUNTY, ARKANSAS.

          STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER

          Susan O. Hickey United States District Judge.

         Plaintiff Earl Forrester ("Plaintiff) and Defendant Lafayette County, Arkansas, ("Defendant") hereby agree and stipulate as follows:

         1. This Stipulated Confidentiality and Protective Order shall apply to any and all documents produced by Plaintiff or Defendant and marked as "Confidential" (the "Confidential Documents").

         2. Plaintiff and Defendant hereby stipulate and agree that the Confidential Documents are confidential unless challenged as provided in paragraph 5 below, and that they shall only be disclosed by the attorneys for Plaintiff and Defendant to the following individuals to the extent the attorneys reasonably deem disclosure necessary for proper litigation:

a. The Court, its employees, court reporters and the jury;
b. Plaintiff or Defendant;
c. Counsel for Plaintiff or Defendant, as well as their paralegals and clerical staff;
d. Outside experts or consultants retained by counsel for Plaintiff or Defendant; and
e. Non-party witnesses in the course of depositions or interviews or preparation for same.

         3. Any person referenced in Paragraphs (a) through (e) who is either shown all or part of a Confidential Document (either directly or indirectly-e.g., by being shown a deposition transcript or a motion to which the Confidential Document has been attached), or who is told about information contained in a Confidential Document, must be told by the attorney at the same time that the Court has ordered that the Confidential Document (or information, if applicable) is confidential, and that the person is not to show the Confidential Document nor convey any information contained in the Confidential Document to anyone else.

         4. Any testimony given at trial or during a deposition concerning a Confidential Document or the contents thereof shall likewise be considered a Confidential Document for the purposes of this Order.

         5. Documents or discovery responses containing Confidential Information disclosed or produced by any party in this litigation are referred to as "Confidential Documents." Except as otherwise indicated below, all documents or discovery responses designated by the producing party as "Confidential" and which are disclosed or produced to the attorneys for the other parties to this litigation ...


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