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Drayton v. McIntosh County

United States District Court, S.D. Georgia, Brunswick Division

February 10, 2017

SARAH FRANCES DRAYTON, et al., Plaintiffs,
MCINTOSH COUNTY, et al., Defendants.

          Jamie L. Crook Reed N. Colfax, Ryan C. Downer, Jia M. Cobb, Jamie L. Crook, RELMAN, DANE & COLFAX, ROBERT B. JACKSON, IV, LLC, Attorneys for Plaintifs

          John E. Bumgartner John E. Bumgartner Richard K. Strickland Bradley J. Watkins BROWN, READDICK, BUMGARTNER, CARTER, STRICKLAND & WATKINS, LLP, Attorneys for Defendants McIntosh County, Sheriff Stephen Jessup, and McIntosh County Board of Tax Assessors

          Julie Adams Jacobs Julie Adams Jacobs, Senior Assistant Attorney General Michelle J. Hirsch, Assistant Attorney General Britany H. Bolton, Assistant Attorney General Alkesh B. Patel, Assistant Attorney General OFFICE OF THE ATTORNEY GENERAL, Attorneys for Defendants State of Georgia, Governor Nathan Deal, Georgia Department of Natural Resources, and Georgia Department of Natural Resources Commissioner Mark Williams



         This Protective Order is issued to facilitate document disclosure and production under the Local Rules and General Orders of this Court and the Federal Rules of Civil Procedure, including Fed.R.Civ.P. 5.2. Unless modified under the terms contained in this Order, this Order shall remain in effect through the conclusion of this litigation. In support of this Order, the Court finds that:

         Discovery in this action may involve the exchange of sensitive materials, including documents that may include information such as individuals' social security numbers, residential addresses, financial records, and other information of a private nature. The Parties intend that private information be kept confidential pursuant to the terms of this Confidentiality Stipulation and Protective Order (“Protective Order”). Information subject to this Protective Order shall not be distributed or otherwise disclosed except as provided herein. To protect the respective interests of the Parties and to facilitate the progress of disclosure and discovery in this case, the following Order should issue:


         I. Scope of this Protective Order

         1. For purposes of this Protective Order, the term:

         “Confidential Material” is defined as information that the producing Party designates in good faith should be protected from disclosure and use outside the litigation because the disclosure and use of such information is restricted by statute or could potentially cause harm to the interests of the parties and/or nonparties. Confidential Material refers to any record, document, tangible thing, testimony, information, or other material disclosed, or to be disclosed, through formal or informal discovery or otherwise in the course of this litigation, that contains: personal data identifiers as listed in this Court's local rules, general orders, or the Federal Rules of Civil Procedure; birth dates; social security numbers; tax payer identification numbers; income tax returns; medical information; psychological information; criminal records; residential addresses; identities of minor children; and the current home or cellular telephone number(s) of any Party, witness, or potential witness in this action. The Parties may move the Court for the inclusion of additional categories of confidential material. This Protective Order does not constitute a ruling on the question of whether any particular document or category of information is properly discoverable, relevant, or admissible, or on any potential objection to the discoverability, relevance, or admissibility of any record.

         2. The confidentiality of medical and psychological information and other private health information is governed by Addendum 1 to this Order.

         II. Designation of Confidential Material

         3. The Parties shall mark Confidential Material that identifies specific individuals as “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.” For any Confidential Material, such as computer data, the medium of which makes such stamping impracticable, the Parties shall mark the diskette case and/or accompanying cover letter as “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.” Initial Disclosures, answers to interrogatories and other responses to discovery requests, if any, that contain protected information shall be marked “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER, ” and shall be subject to the limitations on the use of Confidential Material as set forth herein.

         4. Inadvertent failure to designate any document or material as containing Confidential Material will not constitute a waiver of an otherwise valid claim of confidentiality pursuant to this Protective Order, so long as a claim of confidentiality is asserted within a reasonable time after discovery of the inadvertent failure.

         5. Any Confidential Material produced by the Parties that is designated as Confidential Material shall be used only for purposes of litigating this action, including any subsequent appeals. The defendants, private plaintiffs, and their representatives shall not disclose Confidential Material or any portion thereof to any person or entity not identified in paragraph 6, below.

         6. Except as provided in this Protective Order or otherwise ordered by this Court, any Confidential Material that are marked “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” may be disclosed only to the following persons:

(a) Counsel in this action;
(b) Parties in this action, to the extent disclosure is necessary for this litigation;
(c) Partners, associates, and legal staff of Counsel in this action, to the extent reasonably necessary to render ...

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