United States District Court, N.D. Mississippi, Greenville Division
AGREED PROTECTIVE ORDER
matter comes before the Court on stipulation of the parties
as evidenced below. The following provisions shall govern
Plaintiff, Robbie Johnson, individually, and also on behalf
of Defendant, Quality Restaurant Concepts, LLC d/b/a
Applebee's Neighborhood Grill and Bar, Jane Doe and Kathy
response to discovery in this matter, certain party/ies may
identify or have identified responsive materials that it
considers confidential, proprietary, and sensitive, and that
that it wishes to protect from dissemination outside the
confines of this litigation. This Order shall control the
disclosure and dissemination of such documents and
information, and shall apply to all parties in this case and
to other persons as described herein.
Until further order of the Court or stipulation of the
parties to this action, all disclosures, depositions,
documents, and tangible things, including answers and
responses to interrogatories, responses to requests for
production of documents or admissions, depositions of
employees, former employees, doctors, witnesses or
consultants (hereinafter collectively referred to as
"information"), shall be subject to this Order.
disclosing party shall designate as confidential information
that it has produced or will produce only after a
determination that the information should be protected from
disclosure as sensitive, confidential, or proprietary.
making disclosures or responding to written discovery, the
disclosing party may so designate any portion of its response
which contains information considered confidential by marking
the material as "Confidential - this is subject to the
Protective Order" or "Confidential."
Within five (5) days of receiving the transcript of any
deposition, the disclosing party shall designate any
testimony confidential by notifying opposing counsel in
writing of the page and line numbers of the testimony deemed
confidential. If the disclosing party fails to do so within
five (5) days after receiving the transcript, the deposition
shall be deemed not confidential.
Except with the prior written consent of counsel for the
disclosing party, confidential information may be shown or
disclosed only to the following persons:
a. Any counsel assisting in the prosecution or defense of
b. Employees of counsel assigned to and necessary to assist
counsel in the preparation of this action;
c. Independent experts and consultants retained by counsel
whose assistance is deemed necessary by counsel for the
prosecution or defense of this action, and employees of such
experts and consultants necessary to assist such persons in
performing their duties; and
d. Named parties to the case.
the conclusion of the action, counsel for the parties will
return all copies of the documents marked
"Confidential" to the disclosing party, or make
reasonable efforts to destroy same.
such documents or information shall be used only for the
purpose of litigating this action.
recipient of such confidential materials shall not disclose
the same to any other person to whom disclosure is not
authorized by the terms of the Protective Order. Any
recipient of such confidential information shall exercise
reasonable and appropriate care with regard to the storage,
custody and/or use of such confidential information in ...