United States District Court, W.D. Arkansas, Hot Springs Division
AGREED PROTECTIVE ORDER
ROBERT
T. DAWSON SENIOR U.S. DISTRICT JUDGE.
Before
the Court is the Joint Motion for Protective Order filed by
Happy Valley, LLC (ECF No. 25). The Court finds that no
response is necessary, and the matter is ripe for
consideration.
The
Court finds as follows:
1. The
Parties to this litigation assert during discovery they have
or will disclose or produce documents or information
pertaining to training materials, handbook materials,
manuals, policies, medical records, as well as information
pertaining to present and former applicants and employees of
Defendant that contain confidential information in this
litigation between the Parties.
2. The
Parties assert public dissemination and disclosure of
Confidential Information could damage the Party disclosing or
producing the Confidential Information or could violate the
privacy rights of other non-parties.
3. The
Parties acknowledge Confidential Information includes, but is
not limited to:
(a) home addresses, telephone numbers, social security
numbers, salary or other pay information, and time records of
present and former applicants and employees of Defendant;
(b) certain personnel file documents pertaining to current
and former employees of Defendant, including but not limited
to, applications, rates of pay, insurance coverage
information, benefits information, and personnel attendance
records;
(c) certain business records of Defendant, including, but not
limited to, selection documentation, job descriptions, and
staff records, training materials, handbook materials,
manuals, and policies;
(d) intellectual property, trade secrets, and proprietary
information of Defendant;
(e) financial records of Defendant;
(f) information relating to or identifying current or former
residents of Defendant;
(g) medical records or “Protected Health Information,
” as defined by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), or any applicable State
counterparts, or other records containing individually
identifiable health information belonging to applicants,
current and former employees, and current and former
residents of Defendant; (h) any information designated and/or
protected by any statute or other law as private or
confidential; and
(i) any other information or document that, upon the
reasonable judgment of the Parties, would create a
substantial risk of serious harm to the disclosing Party if
such information disclosed or ...