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Scriber v. Conseco Life Insurance Co.

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

September 28, 2017

MARCIE P. SCRIBER, Trustee of the Ladd J. Scriber Life Insurance Trust, Plaintiff,
v.
CONSECO LIFE INSURANCE COMPANY, Defendant.

          PROTECTIVE ORDER

          D.P. Marshall Jr., United States District Judge.

         With the parties' agreement, and pursuant to Federal Rule of Civil Procedure 26(c), the Court orders:

         1. PURPOSES AND LIMITATIONS

         Disclosure and discovery in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation is warranted.

         Those provisions of the Court's Scheduling Order (Doc. No. 24 at 2-3), including the Court's procedure for discovery disputes set forth therein, are incorporated by reference in this this Order.

         2. DEFINITIONS

         2.1 Party: any party to this action, including any officer, director, employee, representative, agent, consultant, retained expert, outside counsel (and their support staff), or other person or entity acting or purporting to act on behalf or at the direction of any party.

         2.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

         2.3 "Confidential" Information or Items: information (regardless of how generated, stored or maintained) or tangible thing that qualifies for protection.

         2.4 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

         2.5 Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.

         2.6 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential." 2.7 Protected Material: any Disclosure or Discovery Material that is designated as "Confidential." 2.8 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.

         2.9 House Counsel: attorneys who are employees of a Party.

         2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as well as their support staffs).

         2.11 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party's and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party's. This definition includes a professional jury or trial consultant retained in connection with this litigation.

         2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors.

         3. SCOPE

         The protections conferred by this Order cover not only Protected Material (as defined above), but also any information copied or extracted from Protected Material, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties or counsel to or in court or in other settings that might reveal Protected Material.

         4. DURATION

         The Court's authority to enforce this Order will expire one year after the final termination of this litigation; after that, the obligation of the ...


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