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Chadwell v. Lone Star Railroad Contractors Inc.

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

May 14, 2018

LORRAINE CHADWELL, Individually and as the Personal Representative of the ESTATE OF THOMAS DAZEY, Deceased and on behalf of the Wrongful Death Beneficiaries of Thomas J. Dazey, Deceased PLAINTIFFS
v.
LONE STAR RAILROAD CONTRACTORS, INC.; WELLS FARGO RAIL CORPORATION; BNSF RAILWAY COMPANY; JOHN DOE, JOHN DOE CORPORATION I, AND JOHN DOE CORPORATION II; AND STEEL DUST RECYCLING, LLC DEFENDANTS

          Richard T. Donovan, Rose Law Firm, Attorney for Nucor

          Timothy Gaarder, Thomas C. Jones, Grant L. Davis Shawn Foster Timothy Gaarder Tony L. Wilcox, Wilcox Law Firm, Attorneys for Plaintiff

          John P. Lord, Terrence J. O'Toole, WILLIAMS VENKER & SANDERS LLC, ATTORNEYS FOR DEFENDANT LONE STAR RAILROAD CONTRACTORS, INC.

          Joseph P. Pozen, BATES CAREY, LLP, ATTORNEY FOR WELLS FARGO RAIL CORPORATION

          J. Cotton Cunningham BARBER LAW FIRM PLLC, ATTORNEYS FOR WELLS FARGO RAIL CORPORATION

          John W. Grimm, ATTORNEYS FOR WELLS FARGO RAIL CORPORATION

          J. Barrett Deacon DEACON LAW FIRM, P.A., ATTORNEYS FOR BURLINGTON NORTHERN SANTA FE RAILWAY COMPANY

          Laurel Stevenson HADEN, COWHERD & BULLOCK, LLC, ATTORNEYS FOR BURLINGTON NORTHERN SANTA FE RAILWAY COMPANY

          Phil Campbell Haley Heath Burks, ATTORNEYS FOR DEFENDANT STEEL DUST RECYCLING, LLC

          STIPULATION AND PROTECTIVE ORDER

          LEON HOLMES UNITED STATES DISTRICT COURT JUDGE.

         The Parties and non-party, Nucor Corporation ("Nucor"), by and through their respective counsel, respectfully request that this Court enter the following Protective Order as stipulated to by the parties to this action.

         STIPULATION

         1. During discovery in this action, the Parties and/or Nucor may be required to produce documents, answer interrogatories, respond to requests for admissions, and/or provide oral testimony which may reveal trade secrets or other confidential research, development or proprietary commercial information that should not be disclosed other than as designated by the terms of a Protective Order.

         2. Accordingly, the Parties and Nucor request that this Court enter a Protective Order that all discovery responses which contain trade secrets or other confidential research, development or proprietary commercial ...


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