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Andrews v. Fedex Freight Inc.

United States District Court, D. South Carolina, Spartanburg Division

October 17, 2017

Dustin Andrews, Plaintiff,
v.
FedEx Freight, Inc., Defendant.

          Charles J. Hodge, Esq. Hodge & Langley Law Firm, P.C. Attorney for Plaintiff

          Robert D. Moseley, Jr. (Bar No. 64084) Robert T. Green (Bar No. 100308) Attorneys for Defendant

          PROTECTIVE ORDER

          Honorable Mary Geiger Lewis U.S. District Judge

         INTRODUCTION

         Plaintiff Dustin Andrews (hereinafter “Plaintiff”) requested that Defendant FedEx Freight, Inc. (hereinafter “FedEx”) produce documentary material in this matter. FedEx subsequently asserted privilege and objected to the release of its Driver's Manual (“the Manual”) of it on the basis that such materials are confidential and proprietary. Consequently, Plaintiff and FedEx agreed to a consent protective order in this matter that would allow the Plaintiff to obtain the Manual.

         PURPOSE OF PROTECTIVE ORDER

         The purpose of this Protective Order is to facilitate the release and/or use of the Manual, while protecting the confidentiality of this material.

         PROTECTIVE ORDER

         The parties stipulate that the Manual is protected, and therefore, the disclosure and use of that information shall be conducted pursuant to the following conditions:

(1) Non-Disclosure Requirement: Except as provided herein, neither the Manual nor any of the information contained therein shall be disclosed or used by anyone or by any entity for any purpose, without FedEx's explicit written consent.
(A) Specifically Precluded Uses: It is specifically understood and agreed that the Manual shall not be used/disclosed for any data base, index, or similar compilation maintained by any person or entity. It is specifically understood and agreed, however, that the foregoing shall not prohibit the Plaintiff or his attorney from summarizing or compiling the Manual for use in the instant matter only.
(B) Specifically Allowable Uses, Disclosures, and Maintenance: It is specifically understood and agreed that the Manual may be used, and/or disclosed, and/or maintained, without FedEx's consent as may be required to comply with state or federal laws/rules, and court, arbitrator, or administrative order (including subpoenas duces tecum), and in relation to any claim, litigation, and/or proceeding arising out of the alleged injuries that the Plaintiff sustained as a result of the incident that occurred on June 5, 2015, (hereinafter “Subject Incident”), including the following:
(1) for the subject case, including for evaluation, investigation, negotiations, mediation, arbitration, litigation, and/or claims handling;
(2) for subrogation and reimbursement matters concerning the Subject Incident, such as subrogation or reimbursement clams for workers' compensation liens, medical liens, or other insurer's claims for subrogation, ...

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