United States District Court, E.D. Arkansas, Jonesboro Division
MARCIE P. SCRIBER, Trustee of the Ladd J. Scriber Life Insurance Trust, Plaintiff,
CONSECO LIFE INSURANCE COMPANY, Defendant.
Marshall Jr., United States District Judge.
the parties' agreement, and pursuant to Federal Rule of
Civil Procedure 26(c), the Court orders:
PURPOSES AND LIMITATIONS
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
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.
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.
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
"Confidential" Information or Items: information
(regardless of how generated, stored or maintained) or
tangible thing that qualifies for protection.
Receiving Party: a Party that receives Disclosure or
Discovery Material from a Producing Party.
Producing Party: a Party or non-party that produces
Disclosure or Discovery Material in this action.
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.
House Counsel: attorneys who are employees of a Party.
Counsel (without qualifier): Outside Counsel and House
Counsel (as well as their support staffs).
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.
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.
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
Court's authority to enforce this Order will expire one
year after the final termination of this litigation; after
that, the obligation of the ...