Perry v. Fred's Stores of Tennessee, Inc.

Filing 19

Agreed PROTECTIVE ORDER. Signed by Magistrate Judge G. R. Smith on 2/28/17. (wwp)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA

MATTIE PERRY,

)

Plaintiff,
v.

Case No.: 6:16-cv-00154

FRED’S STORES OF TENNESSEE INC. d/b/a
FRED’S SUPER DOLLAR,

Jury Demanded

Defendant.

)
AGREED PROTECTIVE ORDER

Upon good cause shown, and by agreement of the parties, through counsel, the Court
herewith orders that any company records, personnel records, videos, handbooks, training
materials, policy manuals or other documents produced in discovery in this Civil Action,
including excerpts of or compilations from therein (collectively, “the records”) shall be subject to
the following restrictions:
(a)

The records or any copies of the records shall not be circulated to any person
other than counsel, the parties, and the Court;

(b)

The contents of the records shall not be disclosed to any person other than
counsel, the parties, and the Court except for expert witnesses as designated by
the parties;

(c)

The records shall be used only for purposes of the instant litigation;

(d)

At the termination of this Civil Action, including all appeals, or upon the
expiration of the time period for appeal with no appeal having been taken, any
records furnished by any defendant and all copies thereof in the possession of

opposing counsel or parties shall be returned to counsel for the respective
defendant or destroyed with written certification of destruction being provided to
counsel for the respective defendant.

SO ORDERED, this __28th___ of___February___, 2017.
day

M~M
r

~~

G.R. SMITH
UNITED STATES MAGISTRATE
JUDGE
Agreed and Approved:

/s/ Patrick G. Walker
Richard D. Underwood GA Bar No. 291849
Patrick G. Walker
GA Bar No. 110556
F ARRIS B OBANGO B RANAN PLC
999 S. Shady Grove Road, Suite 500
Memphis, Tennessee 38120
901.259.7100
[e-mail]
[e-mail]
Attorneys for Fred’s Stores of Tennessee, Inc.

/s/ George T. Major, Jr.
Patrick T. O’Connor GA Bar No. 548452
George T. Major, Jr. GA Bar No. 619608
O LIVER MANER LLP
218 W. State Street
P.O. Box 10186
Savannah, Georgia 31412
912.236.3311
[e-mail]
[e-mail]
Attorneys for Mattie Perry

2