Carter v. Ameripride Services, Inc.

Filing 14

PROTECTIVE ORDER. Signed by David A. Sanders on 5/17/11. (ncb)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF MISSISSIPPI
WESTERN DIVISION
______________________________________________________________________________
James Stanley Carter,
Plaintiff,
v.
AmeriPride Services Inc.
Defendant.

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Case No. 3:11-cv-00013-MPM -DAS

______________________________________________________________________________
AGREED PROTECTIVE ORDER
______________________________________________________________________________
Pursuant to the agreement of the parties, the Court enters the following Order regarding
production of documents or information by the parties:
1.

Counsel for either party may mark, stamp or otherwise designate documents or

information to be produced as “Confidential”. These designations are to be made in good faith.
It is envisioned that the types of documents or information to be designated as “Confidential”
will include things such as Defendant’s personnel information, information regarding company
investigations, proprietary information, trade secrets, competitively valuable commercial
information, and information produced by Plaintiff regarding himself which is personal or
private.
2.

Unless otherwise agreed by the designating party, or ordered by the Court, the

other party and his/its counsel, or individuals retained by or working with them, shall not
disclose documents or information designated as “Confidential”, and shall not use the documents
or information for any purpose other than in connection with the instant litigation.

3.

If requested by the producing party within 30 days of the conclusion of this

litigation, the other party shall return all produced documents designated as “Confidential” and
copies thereof. Absent a request by the producing party within 30 days of the conclusion of this
litigation, the other party shall destroy all such documents and copies thereof,
4.

This Order does not prohibit either party from filing motions or other Court

documents which include documents or information designated by the other party as
“Confidential.” However, the party intending to file such documents or information will notify
opposing counsel at least five working days before such filing, to permit the other party to seek
agreed or Court-ordered protection by filing under seal or otherwise.
It is so ORDERED.
/s/ David A. Sanders
UNITED STATES MAGISTRATE JUDGE
Date: May 17, 2011.

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APPROVED FOR ENTRY:

/s/ Cary Schwimmer
CARY SCHWIMMER
TN BAR NUMBER 014026
Law Offices of Cary Schwimmer
1922 Exeter, Suite 5
Germantown, TN 38138
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

WAIDE & ASSOCIATES, P.A.
BY: /s/ Jim Waide
MS BAR NUMBER 6857
WAIDE & ASSOCIATES, P.A.
ATTORNEYS AT LAW
POST OFFICE BOX 1357
TUPELO, MISSISSIPPI 38802
TELEPHONE: [phone]
FACSIMILE: 662-842-8056
E-MAIL: [e-mail]

Lead Counsel for Defendant
AmeriPride Services Inc.

Attorneys for Plaintiff

/s/ Cameron Abel
CAMERON ABEL
MS BAR NUMBER 102319
Tollison Law Firm, P.A.
103 North Lamar Boulevard
Post Office Box 1216
Oxford, Mississippi 38655
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Local Counsel for Defendant
AmeriPride Services Inc.

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