United States District Court, E.D. Arkansas, Pine Bluff Division
JACOB D. BULLOCK PLAINTIFF
PACKERS SANITATION SERVICE, INC. LTD., a/k/a PSSI DEFENDANTS
Gates for Paul Byrd Law Firm, PLLC Mr. Paul Byrd Mr. Joseph
Gates Ms. Sara Silzer Paul Byrd Law Firm, PLLC
Steve Crane Crane, Butler & Phillips, PA
Bruce Munson Munson, Rowlett, Moore & Boone, PA
AGREED PROTECTIVE ORDER WITH TYSON FOODS,
S. MILLER, UNITED STATES DISTRICT CHIEF JUDGE.
for Plaintiff and Non-Party Tyson Foods, Inc., have agreed to
handle and protect certain documents requested under Subpoena
pursuant to certain terms.
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
(B) Root Cause Investigation With Corrective Actions Tyson
(C) Accident Investigation with Causal Analysis.
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.
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
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 ...