Fill and Sign the Response Motion Template 497314739 Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF VS. NO.             ,       , AND       DEFENDANTS DEFENDANTS' RESPONSE TO PLAINTIFF'S MOTION FOR ORDER TO COMPEL PRODUCTION OF DOCUMENTS AND REQUEST FOR A PROTECTIVE ORDER COMES NOW, the Defendant(s) in the above styled and numbered civil action, by and through counsel, pursuant to M.R.C.P. 26(c), and move the Court for a Protective Order relieving them of the responsibility to respond to Plaintiff's             ,       , Motion for Order to Compel Production of Documents, and for cause therefore would show unto the Court the following: I. The Defendant(s) admit that they have not produced the following: 1. A complete and up - to - date audit opinion, of the       deposited in the       . There is no       .       County Inmate Funds are deposited in the Mississippi       , which is kept at       , MS. 2. The addresses of persons living in the free - world society who were directly involved in the incidents leading to this Civil Rights Complaint.       has been provided with business addresses where he/she may correspond with all persons directly involved. The Defendant(s) object to providing residential addresses of free - world persons to a convicted felon; home addresses certainly cannot lead to discoverable information. Finally, the Defendant(s) seek a protective Order from the Court to prevent release of such information. Prison officials have a legitimate security interest in preventing       from obtaining this information. 3. The name, titles and addresses of all offenders and officials who were asked to take a polygraph examination prior to             ,       in connection with the investigation of allegations of       by plaintiff. This is not a question asked by Plaintiff in his/her Request to Produce Documents. There were no persons asked to take a polygraph examination prior to             ,       . II. The Defendant(s) submits that they have responded fully to the Plaintiff's Discovery Requests and provided all information to which he/she is entitled. III. The Defendant(s) request this Court to issue a Protective Order relieving any obligation to provide       with residential addresses of the free - world individuals he/she is bringing this Complaint against. Respectfully submitted, _______________________________________       Attorney for       Of Counsel:                         Telephone:       MSB #       Attorney for