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Bullock v. Packers Sanitation Services, Inc. Ltd.

United States District Court, E.D. Arkansas, Pine Bluff Division

October 27, 2017

JACOB D. BULLOCK PLAINTIFF
v.
PACKERS SANITATION SERVICE, INC. LTD., a/k/a PSSI DEFENDANTS

          Joseph Gates for Paul Byrd Law Firm, PLLC Mr. Paul Byrd Mr. Joseph Gates Ms. Sara Silzer Paul Byrd Law Firm, PLLC

          Mr. Steve Crane Crane, Butler & Phillips, PA

          Mr. Bruce Munson Munson, Rowlett, Moore & Boone, PA

          AGREED PROTECTIVE ORDER WITH TYSON FOODS, INC.

          BRIAN S. MILLER, UNITED STATES DISTRICT CHIEF JUDGE.

         Counsel for Plaintiff and Non-Party Tyson Foods, Inc., have agreed to handle and protect certain documents requested under Subpoena pursuant to certain terms.

         1. During the course of litigation of this case, Plaintiff has requested under Subpoena certain documents compiled by Non-Party Tyson Foods, Inc. These documents generally contain certain information that Tyson Foods, Inc. claims as privileged, confidential, sensitive and not available to the general public. The most confidential of these documents are:

(A) Environmental, Health and Safety Services Root Cause Analysis;
(B) Root Cause Investigation With Corrective Actions Tyson Confidential; and,
(C) Accident Investigation with Causal Analysis.

         These records are hereinafter referred to as “Protected Material.” The protection conferred by this Order covers not only the Protected Material described above, but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries or compilations thereof.

         2. For purposes of this case, any such materials shall be maintained as Confidential by counsel and not given, shown, made available, communicated, or distributed in any way to anyone except:

a. The Court and court personnel (including the court having jurisdiction over any appeal);
b. Court reporters used in connection with the litigation;
c. Any person who (i) wrote or received a copy of the document designated confidential before it was furnished in this litigation, or (ii) was present or participated in a meeting or discussion of the protected ...

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