WAL-MART STORES EAST, LP v. Endicott, 81 So. 3d 486

Endicotts filed an amended complaint against Wal‑Mart for alleged prescription negligence.
Discovery sought Wal‑Mart job descriptions and portions of the Pharmacy Operations Manual; confidentiality and trade secrets asserted.
Parties could not agree to a sharing provision allowing respondents’ counsel to share confidential discovery with collateral litigants.
Protective order allowed disclosure to attorneys, staff, and experts in Wal‑Mart prescription‑error cases, with notice and binding agreement requirements.
Wal‑Mart challenged the orders in certiorari, arguing the sharing provision departs from the law and violates trade secret protections; Respondents argued collateral litigation needs justify disclosure.
Trial court orders were granted, Wal‑Mart petitioned for certiorari, and the Florida First District Court of Appeal granted relief, quashing the orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the sharing provision a departure from essential legal requirements?	Wal‑Mart contends the provision is improperly broad and undefined.	Endicott argues the sharing provision aids collateral litigants and should be upheld under protective ordering.	Yes, it departs from essential requirements of law.
Does the order create irreparable harm sufficient for certiorari review?	Wal‑Mart argues dissemination of trade secrets will cause cat‑out‑of‑the‑bag harm.	Endicott contends harm is speculative and not irreparable.	Yes, irreparable harm is shown.

Cordis Corp. v. O'Shea, 988 So.2d 1163 (Fla. 4th DCA 2008) (requires narrowly tailored sharing and balance of interests)
Foltz v. State Farm Mutual Automobile Insurance Co., 331 F.3d 1122 (9th Cir. 2003) (collateral access to discovery must show relevance and discoverability)
Holden Cove, Inc. v. 4 Mac Holdings, Inc., 948 So.2d 1041 (Fla. 5th DCA 2007) (irreparable harm in discovery context must be real, not speculative)