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Dykes v. Cleveland Nursing & Rehabilitation Center

United States District Court, N.D. Mississippi, Greenville Division

December 5, 2017

DANNY DYKES, INDIVIDUALLY AND ON BEHALF OF THE ESTATE AND WRONGFUL DEATH BENEFICIARIES OF JAMES A. DYKES, DECEASED PLAINTIFF
v.
CLEVELAND NURSING & REHABILITATION CENTER and JOHN AND JANE DOES I-X DEFENDANTS

          APPROVED FOR ENTRY: Jason M. Kirschberg GADOW TYLER, PLLC, John F. Hawkins HAWKINS GIBSON, PLLC, David Norquist DAVID NORQUIST LAW OFFICE, PLLC, R. Paul Williams, III WILLIAMS NEWMAN WILLIAMS, PLLC

          COUNSEL FOR THE PLAINTIFF Bradley W. Smith, Clay Gunn (MSB No. 102920), Adria H. Jetton (MSB No. 104094), BAKER, DONELSON, BEARMAN, CALDWELL BERKOWITZ, PC MAILING: Post Office Box 14167 Jackson, Mississippi 39236-4167 COUNSEL FOR THE DEFENDANT

          AGREED PROTECTIVE ORDER

          JANE M. VIRDEN UNITED STATES MAGISTRATE JUDGE

         The Plaintiff, Danny Dykes, Individually and on behalf of the Estate and Wrongful Death Beneficiaries of James A. Dykes, Deceased, has requested that the Defendant produce certain confidential, commercial, and proprietary documents and tangible items (the “Protected Documents”). In order to preserve and maintain the confidentiality of such documents, the parties have agreed to the terms contained in this Order.

         1. The Defendant has objected to producing the Protected Documents because they contain confidential and proprietary information or trade secrets (“Confidential Information”) of importance and value to the Defendant.

         2. The Plaintiff and the Defendant acknowledge that disclosure of such Confidential Information to, or use of such Confidential Information by, any person or entity not a party to the lawsuit, or in any context other than this lawsuit, could cause commercial or financial harm to the Defendant.

         3. Recognizing the need to protect the Confidential Information contained in the Protected Documents, the parties have agreed to the following provisions.

         4. The documents subject to this Order shall hereafter and for the remainder of this litigation be referred to as “Protected Documents.” When used in this Protective Order, the word “documents” means all written material, videos, and all other tangible items. The Protected Documents shall be marked by the Defendant as “Pursuant to Protective Order, ” “Confidential, ” “Protected, ” or identified in written discovery responses or other documents with specific Bates numbers or other designation as being produced subject to this Protective Order. Any "Confidential" indication or designation shall apply not only to the original materials, but also to all copies, excerpts, abstracts, analyses, and summaries thereof.

         5. The term "disclosure" includes, but is not limited to, the transmittal of information, whether verbal, written, typed, printed, gestured or by other manner, regarding the content of the Protected Documents.

         6. The Protected Documents are subject to this Protective Order and may, even though protected, be distributed, shown, and disseminated to the following persons (“Qualified Persons”):

(a) The Plaintiff and Plaintiff's counsel of record in this case, including other members of counsel's law firm;
(b) Employees of Plaintiff's counsel;
(c) Experts and consultants retained by the Plaintiff for the preparation or trial of this case, provided that no disclosure shall be made to an expert or consultant who is ...

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