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Johnson v. Quality Restaurant Concepts, LLC

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

November 14, 2018

ROBBIE JOHNSON PLAINTIFF
v.
QUALITY RESTAURANT CONCEPTS, LLC d/b/a APPLEBEE'S NEIGHBORHOOD GRILL AND BAR, JANE DOE and KATHY SEZNACK DEFENDANTS

          AGREED PROTECTIVE ORDER

         This 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 Seznack.

         1. In 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.

         2. 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.

         3. The 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.

         4. In 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."

         5. 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.

         6. 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 this action;
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.

         7. At 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.

         8. Any such documents or information shall be used only for the purpose of litigating this action.

         9. Any 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 ...


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