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Marziale v. Correct Care Solutions, LLC

United States District Court, E.D. Arkansas, Pine Bluff Division

September 5, 2018

CHRISTINA MARZIALE, Individually and as mother of Baby Boy Marziale; and DANA McLAIN, Administrator of the Estate of Elaine Marziale PLAINTIFFS
v.
CORRECT CARE SOLUTIONS, LLC; STEPHEN COOK; and MAKITA LaGRANT DEFENDANTS

          SUTTER & GILLHAM, P.L.L.C. Attorneys at Law

          Luther Oneal Sutter Attorney for the Plaintiff

          Fuqua Campbell, P.A. Attorneys at Law Attorneys for Defendant, Correct Care Solutions, LLC

          Ken Cook MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C. Attorneys for Defendants Stephen Cook and Makita LaGrant

          STIPULATED PROTECTIVE ORDER

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

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. The parties agree to this Stipulated Protective Order, which is consistent with Fed.R.Civ.P. 26(c). It does not confer blanket protection on all disclosures or responses to discovery. The protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment. It does not presumptively entitle parties to file confidential information under seal.

         2. "CONFIDENTIAL" MATERIAL

         "Confidential" material includes the following documents and tangible things produced or otherwise exchanged:

A. Confidential information in personnel files of employees of Correct Care Solutions, LLC ("CCS"). This designation includes, but is not limited to, such categories of information as medical information, social security numbers, financial information, unlisted phone numbers, and other nonpublic personal identifiers as are protected by law.
B. CCS's policies and procedures and non-public business records, which are proprietary and confidential business information, as contemplated by Fed.R.Civ.P. 26(c)(1)(G), excluding documents subject to disclosure under the Arkansas Freedom of Information Act.
C. CCS records identifying non-parties and their personal information, including, but not limited to other inmates and employees of non-parties;
D. Proprietary software used by CCS in business activities.

         Designation of these categories as Confidential does not make any particular document discoverable.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material. Protections conferred by this order do ...


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