United States District Court, E.D. Arkansas, Western Division
Brian Whitley. Individually, and on Behalf of All Others Similarly Situated PLAINTIFF
v.
Baptist Health; Baptist Health Hospitals Diamond Risk Insurance. LLC; Continental Casualty Company; Admiral Insurance Company; Admiral Indemnity Company; Ironshore Indemnity. Inc.; Ironshore Specialty Insurance Company DEFENDANTS
Robert
L. Henry, IIII, James D. Robertson, Barber Law Firm PLLC,
Attorneys for the Baptist Defendants and Defendant Diamond
Risk Insurance LLC.
David
P. Glover, David Chan Jung, Wright, Lindsey & Jennings
LLP, Attorneys for Defendant Continental Casualty Company.
Campbell & Grooms, PLLC, Donald K. Campbell, III BAILEY
& OLIVER LAW FIRM, Sach D. Oliver, Frank H. Bailey, T.
Ryan Scott, Geoff D. Hamby, HENINGER GARRISON DA VIS LLC, W.
Lewis Garrison Jr., Erik S. Heninger, Jeffrey P. Leonard,
Attorneys for Plaintiff.
Jeffrey W. Puryear, Ryan M. Wilson, Womack Phelps, Puryear
Mayfield & McNeil, P.A., Attorneys/or RevClaims. LLC.
AMENDED AGREED PROTECTIVE ORDER
Hon.
D.P. Marshall, United States District Judge.
The
purpose of this amendment is to extend the confidentiality
protections and obligations of the existing Agreed Protective
Order (Dkt. # 55) to documents and information obtained from
any non-parties to this litigation, including non-party
RevClaims, LLC. The parties to this case and all other
non-party signatories to this Order agree to protect the
confidentiality of certain information (including deposition
testimony) and documents (including documents stored in
electronic format) that may be discovered or offered into
evidence at the trial of this case. The parties and
signatories agree that the confidentiality of such
information and documents shall be preserved under the terms
of this Protective Order:
1. It
is agreed that material provided by any of the parties or
signatories, which they deem confidential, shall be disclosed
only to the following individuals, each of whom shall be
required to read this Protective Order and agree to abide by
these terms before being given any of the information:
a. Counsel for plaintiff and counsel for defendants engaged
in this litigation and their respective staff, to the extent
reasonably necessary:
b. The parties to the litigation, including their employees,
employers and experts;
c. All witnesses, whether testifying in depositions,
hearings, or at trial;
d. Court personnel, any mediator involved in this action, and
employees of any such mediator; and
e. Any other individuals included by order of the Court.
Documents
produced by the parties or signatories to which this
Protective Order is applicable shall be stamped
"CONFIDENTIAL."
2. The
inadvertent production, without designation as confidential,
of information or a document intended to be designated as
confidential shall not waive the producing entity's right
to so designate such document or information. Any information
or documentation that is inadvertently produced without being
designated as confidential shall be, upon written ...