United States District Court, E.D. Arkansas, Pine Bluff Division
CHRISTINA MARZIALE, Individually and as mother of Baby Boy Marziale; and DANA McLAIN, Administrator of the Estate of Elaine Marziale PLAINTIFFS
CORRECT CARE SOLUTIONS, LLC; STEPHEN COOK; and MAKITA LaGRANT DEFENDANTS
& GILLHAM, P.L.L.C. Attorneys at Law
Oneal Sutter Attorney for the Plaintiff
Campbell, P.A. Attorneys at Law Attorneys for Defendant,
Correct Care Solutions, LLC
Cook MITCHELL, WILLIAMS, SELIG, GATES & WOODYARD, P.L.L.C.
Attorneys for Defendants Stephen Cook and Makita LaGrant
STIPULATED PROTECTIVE ORDER
Marshall, Jr. United States District Judge.
PURPOSES AND LIMITATIONS
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.
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.
of these categories as Confidential does not make any
particular document discoverable.
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