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Hicks v. Lindsey Management Co., Inc.

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

July 30, 2019

JORDAN HICKS, individually and on behalf of all others similarly situated PLAINTIFF


          Kristine G. Baker, United States District Judge

         Before the Court is a joint motion for protective order (Dkt. No. 65). For good cause shown, the Court grants the parties' joint motion for protective order (Id.). The parties have agreed to, and, accordingly, the Court orders, the following conditions:

         1. This Stipulated Protective Order (“Order”) shall be applicable to and shall govern the production and exchange of all documents, records, answers to interrogatories, depositions, responses to requests for admissions, exhibits, and all other discovery given or made in this action by any party, as well as pleadings, testimony adduced at depositions or hearings, matters in evidence, and all other information exchanged or furnished in this action by the parties that is marked and designated as “Confidential.” 2. Confidential Information, as later defined herein and obtained by either party in this action, shall be used only for the purpose of this litigation and for no other purposes whatsoever, and shall not be given, shown, made available, or communicated in any way to anyone except Qualified Persons, as herein defined. In the event that any Confidential Information and/or documents subject to this Order are used in any court proceeding in this litigation, it shall not lose its confidential status through such use, and the party using such confidential material shall take all reasonable steps to maintain its confidentiality during such use.

         3. “Confidential Information” shall be deemed to include, without limitation: personally identifying information for current and former employees and residents of facilities owned by, managed by, or affiliated with Lindsey Management Co., Inc.; personnel files; financial and payroll information; proprietary information; and other information agreed upon by the parties or deemed by the Court to be confidential in nature. The parties will designate this information as “Confidential” with the method of designation set forth in the letter of transmittal.

         4. Any Confidential designation is subject to challenge. The following procedures shall apply to any such challenge.

a. A party who contends that Information designated Confidential is not entitled to such treatment shall give written notice to the party who affixed the designation of a challenge to the designation. The party who so designated the Information shall have ten (10) days from receipt of the written notice to respond. If no response is made or if the dispute cannot be resolved without judicial intervention, following a meet and confer, the party challenging the Confidential designation may petition the Court for a determination of the propriety of the Confidential designation.
b. Notwithstanding any challenge to the designation of Information as Confidential, all Information previously designated Confidential shall continue to be treated as such and as subject to the full protections of this Order until one of the following occurs:
i. The party who claims that the Information is subject to Confidential treatment withdraws such designation in writing;
ii. The Court rules that the Information should no longer be designated as Confidential; or
iii. The Court makes some other ruling governing the use of and protections afforded the Information.
c. Challenges to designations of Information as Confidential may be made at any time and are not waived by the failure to raise the challenge at the time of initial disclosure or designation.

         5. Portions of depositions shall be deemed Confidential only if designated as such when the deposition is taken or within seven (7) business days after receipt of the transcript.

         6. In the event a party seeks to file any Confidential Information that is subject to protection under this Order with the Court, that party shall take appropriate action to ensure that the Confidential Information receives proper protection from public disclosure. Any party desiring to file a document under seal, or requesting that a document or documents be filed under seal, must first obtain leave from the Court in order to file the document under seal, or to require that the document or documents be filed under seal. It shall be within the sole discretion of the Court to determine whether said document or documents must be filed under seal.

         7. Except with the prior written consent, or pursuant to further order of this Court on motion with notice to the opposing party, no Confidential Information may be disclosed to any person other than “Qualified Persons” who shall be defined to include plaintiffs, plaintiffs' counsel, defendants, defendants' counsel, employees of counsel for the parties (to the extent necessary), employees of defendants involved in the defense of this ...

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