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Thompson v. Union Pacific Railroad Co.
United States District Court, E.D. Arkansas, Western Division
October 2, 2019
KENYA THOMPSON PLAINTIFF
UNION PACIFIC RAILROAD COMPANY DEFENDANT
P. McKay Khayyam M. Eddings Joshua C. Ashley FRIDAY, ELDREDGE
& CLARK, LLP Attorneys for Defendant
G. Wolff Scott M. Gershenson SCHLICHTER, BOGARD & DENTON,
LLP Attorneys for Plaintiff
WEBBER WRIGHT UNITED STATES DISTRICT JUDGE
the Court is a Joint Motion for Protective Order. Upon
consideration, the Court finds that the motion should be and
hereby is GRANTED. The Court enters the following Protective
Order as proposed by the parties:
parties have information to disclose which may require
protection due to its confidential or proprietary nature.
Accordingly, the parties agree:
1. Scope. All documents produced in the
course of discovery, including all responses to discovery
requests, all deposition testimony and exhibits, other
materials which may be subject to restrictions on disclosure
for good cause and information derived directly therefrom
(hereinafter collectively “documents”), shall be
subject to this Order concerning confidential information as
set forth below.
2. Form and Timing of Designation. A party
may designate documents as confidential and restricted in
disclosure under this Order by placing or affixing the words
“CONFIDENTIAL” on the document in a manner that
will not interfere with the legibility of the document and
that will permit complete removal of the designation.
Documents shall be designated CONFIDENTIAL prior to or at the
time of the production or disclosure of the documents. The
designation “CONFIDENTIAL” does not mean that the
document has any status or protection by statute or otherwise
except to the extent and for the purposes of this Order.
3. Documents Which May be Designated. Any
party may designate documents as CONFIDENTIAL upon making a
determination that the documents contain information
protected from disclosure by statute or that should be
protected from disclosure as confidential personal
information, medical or psychiatric information, trade
secrets, personnel records, proprietary, or such other
sensitive commercial information that is not publicly
4. Protection of Confidential Material.
a. General Protections. Documents designated
CONFIDENTIAL -under this Order shall not be used or disclosed
by the parties, counsel for the parties or any other persons
identified in Paragraph 4(b) for any purpose whatsoever other
than to prepare for and to conduct discovery and trial in
this action, including any appeal thereof.
b. Limited Third-Party Disclosures. The
parties and counsel for the parties shall not disclose or
permit the disclosure of any CONFIDENTIAL documents to any
third person or entity except as set forth in subparagraphs
(i)-(v). Subject to these requirements, the following
categories of persons may be allowed to review documents that
have been designated CONFIDENTIAL:
i. Counsel. Counsel (or the parties and
employees and agents of counsel) who have responsibility for
the preparation and trial of the action;
ii. Parties. Parties and employees of a
party to this Order.
iii. Court Reporters and Recorders. Court
reporters and recorders engaged for ...
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