Judge, dissenting.
This is a proceeding for an extraordinary writ. The majority opinion has not identified any legal authority compelling the conclusion that the circuit court acted in excess of its jurisdiction, that it abused its discretion, or that any party will suffer irreparable harm if the circuit court’s ruling is left undisturbed. Therefore, I respectfully dissent.
The majority concludes that Ford relied on the continuing validity of the non-sharing order and that such reliance is the primary consideration in assessing the circuit court’s modification of the order. While reliance on a protective order is a significant factor in examining the propriety of a decision to modify the order, the issue of reliance is not necessarily the dispositive consideration. In addition to reliance, courts also take into account efficiency concerns and the public interest in open access to records and documents. See Wilk v. American Medical Ass’n, 635 F.2d 1295 (7th Cir.1980). Protective orders may also be modified to streamline the litigation of similar issues in other cases. See Meyer Goldberg, Inc. of Lorain v. Fisher Foods, Inc., 823 F.2d 159, 164 (6th Cir.1987). Therefore, a significant factor for many courts is whether the discovery sought will eliminate the need for duplicative discovery. Wilk, 635 F.2d at 1300.
In this case, the circuit court lifted the non-sharing order so as to permit other parties in virtually identical litigation to efficiently access the very same documents that Ford produced in this case. Though produced under a protective order, the fact remains that neither the suspension orders nor the engineering documents were found to be absolutely privileged from discovery. The only effect of lifting the non-sharing order is that the documents will be available in other cases while still being protected from disclosure to competitors. These efficiency concerns provide a reasonable basis for the circuit court’s decision to lift the non-sharing order. See, e.g., Grove Fresh Distributors, Inc. v. Everfresh Juice Co., 24 F.3d 893, 896 (7 Cir.1994) (“where a third party wishes to modify a protective order so as to avoid duplicative discovery in collateral litiga*590tion, policy considerations favoring the efficient resolution of disputes justifies modification unless such an order would tangibly prejudice substantial rights of the party opposing modification”).
The majority also concludes that Ford’s reliance on the non-sharing protective order was obvious because Ford consistently objected to plaintiffs’ discovery requests and motions. Ford’s decision to vigorously litigate discovery issues does not necessarily imply that Ford is entitled to perpetual reliance on the circuit court’s initial resolution of the discovery dispute. When assessed with an eye toward the efficiency concerns expressed in eases such as Meyer Goldberg and Wilk, Ford’s consistent objections militate in favor of lifting the non-sharing order so as to streamline the litigation of other similar claims against Ford.
Prohibition is an extraordinary writ and should issue only if the facts and circumstances of a particular case demonstrate unequivocally that there exists an extreme necessity for preventative action. Derfelt v. Yocom, 692 S.W.2d 300, 301 (Mo.banc 1985). The discovery issues in the case are, at the very least, fairly debatable. Neither the case law nor the facts of this case compel the conclusion that the court abused its discretion and that there is an extreme necessity for preventative action. Therefore, I would quash the preliminary writ.