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Parker v. BASF Corp.

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

May 17, 2018

LATOYA PARKER, Individually, and on behalf of herself and others similarly situated, Plaintiff,
v.
BASF CORPORATION, a Delaware Corporation Defendant.

          Gordon E. Jackson* (TN Bar No. 08323) J. Russ Bryant* (TN Bar No. 033830) Paula R. Jackson* (TN Bar No. 20149) JACKSON, SHIELDS, YEISER & HOLT COUNSEL FOR PLAINTIFF AND ALL OTHERS SIMILARLY SITUATED,

          Michael A. Correll (with permission) Michael A. Correll Morgan, Lewis & Bockius LLP, Paulo B. McKeeby Morgan, Lewis & Bockius LLP, Audrey Calkins Ogletree, Deakins, Nash, Smoak & Stewart, P.C. COUNSEL FOR DEFENDANT BASF CORPORATION

          AGREED JOINT PROTECTIVE ORDER

         WHEREAS, parties and non-parties to this action ("Litigation"), have been or may be requested in the course of discovery or other proceedings to produce or disclose testimony, documents, or other information (“Discovery Material”) that one or more of the parties consider to be private, confidential, or proprietary); and

         WHEREAS, Plaintiff Latoya Parker, on behalf of herself and others similarly situated (collectively “Plaintiffs”), and Defendant BASF Corporation (collectively, the “Parties”), have agreed, by their undersigned attorneys, to set forth procedures for, and rules governing, the use of such Discovery Material in this Agreed Joint Protective Order (the “Order”);

         The parties hereby stipulate and agree as follows:

         NON-DISCLOSURE OF ALL DOCUMENTS STAMPED CONFIDENTIAL

         1. The parties to this action agree to the following conditions regarding the treatment of Discovery Material that one or more parties consider to be private, confidential or proprietary with respect to the above-styled action and any resulting appeals or retrials (collectively, “the Litigation”).

         2. If, in the course of discovery or other proceedings in this action, Defendants, Plaintiffs, any other party to the Litigation, or any third party, produces or discloses Discovery Material they deem to be private, confidential, or proprietary, the producing party may designate such Discovery Material as "Confidential." Discovery Material designated as Confidential, and all copies, summaries, or extracts thereof, shall be referred to herein as "Confidential Material" and shall be subject to all the terms of this Order.

         3. All Confidential Material produced in discovery in the Litigation shall be used solely for purposes of the Litigation and for no other purpose.

         4. To the extent the Parties have produced documents or information in the Litigation prior to entering into this Order, the Producing Party may retroactively designate any such documents or information as Confidential Material by notifying the Requesting Party of such designation.

         5. For purposes of this Order, the term “document(s)” means all written, recorded, electronic, or graphic materials, whether produced or created by a party or another person, whether produced pursuant to the Federal Rules of Civil Procedure, subpoena, by agent, or otherwise. Any person in possession of Confidential Material shall maintain it in a reasonable and appropriate manner so as to avoid disclosure of its contents in any manner not permitted by this Order.

         6. A hard copy document may be designated as Confidential by stamping or marking or otherwise identifying on the face of the document that it is “Confidential.” Electronically stored information and documents may be designated as Confidential through a marking of “Confidential” in the title of a .pdf version of the document, on the first page of the electronic .pdf document, and/or through a designation in writing from the producing party that it deems the information and documents to be Confidential pursuant to this Order. If a document (other than a deposition or hearing transcript) is designated as Confidential on the initial page of the document, then the entire document will be presumed to be Confidential, unless otherwise indicated on the first page of the document. All or part of a deposition or hearing transcript may be designated Confidential by a statement on the record by counsel requesting the designation, or by a letter to all counsel of record prior to the filing of such deposition with the Court or its use at trial, in a hearing, in deposition or in any other manner in connection with this Litigation. Additionally, a party may, at its election, designate any deposition transcript Confidential in its entirety pending receipt and review of the final transcript. Such designation shall be stated on the record during the deposition and shall persist until thirty days after receipt of the final deposition transcript from the court reporter.

         7. The designation of documents or other forms of information as Confidential under this Order does not create any presumption for or against the confidentiality of such information where the issue is presented to the Court for determination.

         8. Confidential Material shall not be disclosed, except as provided in paragraph 9 below, except upon prior ...


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