Document rxapoxQYwLprq8OQLLwG9jDpq

IN THE CIRCUIT COURT TWENTIETH JUDICIAL CIRCUIT ST. CLAIR COUNTY, ILLINOIS FRANCES E. KEMNER, et al., Plaintiffs V MONSANTO COMPANY Defendant. No. 80-L-970 PROTECTIVE ORDER Upon the Motion of Defendant Monsanto Company, the Court having been advised in the premises, it is hereby ORDERED as follows: 1. Whereas this Court's discovery orders in the aboveentitled cause may require Monsanto Company to disclose certain documents prepared in anticipation of litigation in other cases pending against it which are not subject to discovery in those cases, the Court finds that Monsanto Company is entitled to a protective order restricting the use of such information to this litigation. 2. Monsanto Company may designate as work product material subject to this protective order any documents prepared in anticipation of litigation in other cases. Such designation may be made by marking documents supplied to Plaintiffs with the notation "Federal Work Product - Subject to Protective Order", or by any other means which reasonably informs the parties that the documents are subject to the terms.of this Order. 3. In the event that Plaintiffs'desire 'to dispute Monsanto Company's designation of any document /as subject to this Protective Order, Plaintiffs shall abide .by ..the'terms of this Order respecting the confidentiality of same.unless or until the Court finds, upon motion duly made and.presented, that said document was incorrectly designated as work product information. 4. All material subject to this Order is to be given to counsel for Plaintiffs and shown or disclosed only to the - individual Plaintiffs and to no other persons. Said material is to be used only for purposes of this case and for no other purpose. 5. Upon the request of Monsanto Company made at the conclusion of this action, all documents subject to this Order (including copies thereof and extracts therefrom) shall promptly be returned to Monsanto Company. 6. Nothing in this Order shall be construed to regulate the conduct of the actual trial of this case, nor to limit the right of any party to seek amendments hereto, or to seek additional protective orders pertaining to pretrial proceedings and trial. ENTERED this _______ day of ______________ , 1985. Judge CERTIFICATE OF SERVICE' The undersigned certifies that, a jtrue and accurate copy of the foregoing was hand-delivered .this -6th; day of May, 1985, to th following attorneys of record:' - Mr. Rex Carr Mr. Jerome Seigfreid 109 S. High Street Belleville, Illinois 62221 -... v; . y V / 7.' ''.v-' , 'l ;