Milbry v. Beverly HC Tyson

Filing 51

AGREED PROTECTIVE ORDER as further set out in order. Signed by Honorable Susan Russ Walker on 10/9/2008. (cb, )

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IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION LEOLA MILBRY; as the Personal Representative of the Estate of EARLY MILBRY, deceased, Plaintiff, vs. GGNSC Montgomery, LLC, et al., Defendant. * * * * * * * * * * * * NO. 2:07-cv-837-MEF (WO) AGREED PROTECTIVE ORDER COMES NOW Leola Milbry, as the Personal Representative of the Estate of Early Milbry, deceased, and GGNSC Montgomery, LLC, by and through undersigned counsel, and enter into this agreed protective order, showing unto the court the following: 1. The subject matter of this litigation related to the care and treatment given to Early Milbry by Tyson Manor. 2. Plaintiff has requested disclosure of certain information, including several of Tyson Manor's Policy and Procedure Manuals. 3. Plaintiff has requested disclosure of certain information, including materials provided to employees in connection with training. 4. Defendant recognizes the legitimate discovery interest of Plaintiff, but desires protection, within the content of this litigation, from the disclosure of Defendants' policy and procedure manuals and training materials to those outside the parameters of this litigation. Accordingly, because of the above representations, the parties agree to the following protective order: 1. The terms of this protective order shall apply to the Defendant's Policy and Procedure Manuals and training materials. 2. All material subject to this order shall not be reproduced or made available to anyone outside of this litigation, except to experts involved in this matter, and that all originals and all copies of this material will be returned to us at the conclusion of this matter and shall not be used in any other action against the named defendant in this action. /s W. Benjamin Broadwater W. BENJAMIN BROADWATER, ESQ. Attorney for GGNSC Montgomery, LLC ALFORD, CLAUSEN & McDONALD, LLC One St. Louis Centre, Suite 5000 Mobile, AL 36602 /s Valerie Rucker Russell JOCK M. SMITH, ESQ. VALERIE RUCKER RUSSELL, ESQ. Attorneys for Plaintiff COCHRAN, CHERRY, GIVENS & SMITH, P.C. 306 North Main Street Post Office Box 830419 Tuskegee, Alabama 36083 /s Gail Swan Akin GAIL SWAN AKIN, ESQ. VICKI LACHNEY GILLIAM, ESQ. Attorneys for Plaintiff AKIN GILLIAM PLLC 134 Fairmont Street, Suite C Clinton, Mississippi 39056 2 So ordered. Done, this 9th day of October, 2008. /s/ Susan Russ Walker SUSAN RUSS WALKER CHIEF UNITED STATES MAGISTRATE JUDGE 3

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