Fill and Sign the Pursuant to Rule 26c7 of the Alabama Rules of Civil Procedure it is Hereby Form

IN THE CIRCUIT COURT OF __________ COUNTY, ALABAMA _________________ * * Plaintiff,* * VS. *CIVIL ACTION NO.: * _________________ *CV-_______________ * Defendant. * PROTECTIVE ORDER Pursuant to Rule 26(c)(7), of the Alabama Rules of Civil Procedure, IT IS HEREBY ORDERED, ADJUDGED AND DECREED:1. That all documents and other information, including the substance and content thereof, produced by _____________________________________________________ (hereinafter “___________________”) in response to formal or informal discovery in this litigation, shall be subject to the terms of this Order of confidentiality as set forth below.2. For the purpose of this Protective Order, “Confidential Information” means those documents and written responses provided by __________________ in response to any discovery requests that are designated in good faith as confidential by ____________________ by so indicating on the face of the writing or in any other reasonable manner appropriate to the form in which the Confidential Information is made available to the other parties, including a designation such as “PRODUCED PURSUANT TO PROTECTIVE ORDER”. This Protective Order shall apply to such documents and written responses even if they are marked as deposition exhibits. 3.Information and documents subject to this Order may be disclosed only to (a) a party; (b) attorneys for a party and their paralegal and clerical staffs; (c) experts retained by a party and his attorneys in connection with trial preparation or testimony in this action; and (d) attorneys representing plaintiffs in other cases against _________________________ involving the same allegations if a similar protective order is in place in those cases that would allow the sharing of documents with the plaintiffs in this case.Except as provided above, disclosure shall be made to such person only as necessary for the prosecution of this lawsuit and only after the person to whom disclosure is made has been provided with a copy of this Order and has agreed to be bound by it. Any person, including an expert, to whom disclosure or circulation of Confidential Information is to be made shall, prior to such disclosure or circulation, sign a copy of the Protective Order and agree to abide by and be bound by its terms. Confidential Information shall not be disclosed to any person or in any manner not specified in this Order or used for any purpose other than the prosecution of this lawsuit.4. All counsel shall be deemed to have acknowledged that they are personally bound by this Order by virtue of their appearance in this litigation Any and each other individual to whom the disclosure or circulation of Confidential Information is to be made shall, prior to such disclosure or circulation, (a) be informed of the existence of this Protective Order, (b) be provided with a copy hereto, and (c) be instructed that such Confidential Information is to be used exclusively for the preparation for and the trial of this action and, further, that such Confidential Information is to be disclosed only to such counsel and other persons as are designated and contemplated by paragraph three of this Protective Order. 5.When the party producing a confidential document declares it confidential, that document shall remain confidential until the court rules otherwise. In the event the opposing party challenges the confidentiality of a document by motion, the burden shall be on the party claiming confidentiality to demonstrate the need for protection.6. Nothing in this Protective Order shall be deemed a waiver of _______________________'s rights to oppose discovery on grounds other than that the requested information constitutes or contains Confidential Information into evidence at the trial of this action.7. The provisions of this Protective Order shall not be construed to present any party from using Confidential Information in connection with the trial, any hearing or other public proceeding in this matter, provided that before any party so uses any Confidential Information, all reasonable steps shall be taken by the parties to maintain the confidentiality of the Confidential Information under seal of this Court.8. Within thirty (30) days after the conclusion of this action, all Confidential Information and all copies thereof shall be returned to counsel for ________________________, and held for four (4) years, with Plaintiff's attorneys to have access upon reasonable notice for use in future litigation in related cases; and, as the parties may agree, for such other purposes as may be reasonable under the circumstances. Plaintiff's attorneys may use the confidential information furnished in this case in other cases against ____________________ where Plaintiff's attorneys are retained as counsel for Plaintiffs.SO ORDERED this __________ day of ____________________, ___________. ____________________________________________ CIRCUIT JUDGE cc:Counsel of Record