Brown v. Wal-Mart Real Estate Business Trust et al

Filing 25

AGREED PROTECTIVE ORDER. Signed by Magistrate Judge Juliet E. Griffin on 5/19/14. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.)(dt)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
RICHARD BROWN,
Plaintiff,
VS.
WAL-MART STORES EAST, L.P.
d/b/a “Wal-Mart Store #659",
Defendant.

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No. 3:13-CV-00479
JUDGE TRAUGER
MAGISTRATE JUDGE GRIFFIN
JURY DEMANDED

AGREED PROTECTIVE ORDER
It appears to the Court that plaintiff has requested certain
documents from defendant (“Wal-Mart”), containing confidential
information.
It further appears to the Court that pursuant to Rule 26(c) of
the Federal Rules of Civil Procedure, it is agreed by plaintiff, as
evidenced by the signature of plaintiff’s counsel below, that
certain documents, written materials and information shall be
provided by Wal-Mart to plaintiff in this case through discovery,
subject to the following conditions:
1.

This protective Order shall apply only to those documents
which are designated as “confidential” and not to all
documents produced by Wal-Mart;

2.

Use of any confidential documents and written materials
(and the information contained therein) provided by WalMart to plaintiff is limited solely to the prosecution
and defense of this action to its conclusion or appeal;

3.

Any confidential documents and information provided to
plaintiff will not be released or disclosed by any
counsel or plaintiff to any person at any time, except as
required in the prosecution or defense of this action;

4.

Due to Wal-Mart’s concern for protecting the
confidentiality of the information provided to plaintiff,
any information so provided to plaintiff’s counsel will
not be released or disclosed by plaintiff’s counsel or
others to any person not a party to this action without
permission of Wal-Mart, unless ordered by the Court.
Plaintiff’s use of the confidential information provided
by Wal-Mart is limited solely to the prosecution and
defense of this action;

5.

In the event copies are made pursuant to the terms of
this Order, the mark “confidential” shall remain on each
such copy;

6.

All documents and written materials marked confidential
and provided by Wal-Mart to plaintiff’s counsel, as well
as

photocopies

thereof,

shall

be

destroyed

at

the

conclusion of this action.
7.

All counsel and their clients are ordered to respect the
spirit and letter of this protective order.

8.

Plaintiff retains the right to challenge by Motion a
labeling of “confidential” should such be improper for
any particular document.

IT IS SO ORDERED on this 19th day of May, 2014.

__________________________________
JUDGE
APPROVED FOR ENTRY:
s/ Meredith L. Hiester
G. Andrew Rowlett, No. 16277
Meredith L. Hiester, No. 30183
HOWELL & FISHER, PLLC
Court Square Building
300 James Robertson Parkway
Nashville, TN 37201-1107
#615/244-3370
[e-mail]
[e-mail]
Attorneys for Defendants

s/ Michael K. Smith (with express permission by M. Hiester)
Michael K. Smith, No. 17155
144 Second Avenue North, Suite 150
Nashville, TN 37201
#615/620-5833
[e-mail]
Attorney for Plaintiff

CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was served by the
Electronic Court Filing System upon Michael K. Smith, 144 Second
Avenue North, Suite 150, Nashville, TN 37201, on this the 14th day
of May, 2014.

S/ Meredith L. Hiester