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Holloway v. Traxion, Inc.

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

July 19, 2018

TOMMY HOLLOWAY, Plaintiff,
v.
TRAXION INC., Defendant.

          RAHIMI, HUGHES & PADGETT, LLC JOSEPH Y. RAHIMI II, JOHN A. HUBERT GEORGIA BAR NO. 122388 ATTORNEYS FOR DEFENDANT

          WARSHAUER LAW GROUP, P.C., MICHAEL J. WARSHAUER GEORGIA BAR NO. 018720 ATTORNEY FOR PLAINTIFF

          PROTECTIVE ORDER

         The parties have requested that the Court enter the following Protective Order. Therefore, the Court enters the following Order:

         1. Definitions. As used in this protective order:

(a) "attorney" means an attorney who has appeared in this action;
(b) "confidential document" means a document designated as confidential under this protective order;
(c) to "destroy" electronically stored information means to delete from all databases, applications, and file systems so that the information is not accessible without the use of specialized tools or techniques typically used by a forensic expert;
(d) "document" means information disclosed or produced in discovery, including at a deposition;
(e) "notice" or "notify" means written notice;
(f) "party" means a party to this action; and
(g) "protected document" means a document protected by a privilege or the work-product doctrine.

         2. Designating a Document or Deposition as Confidential.

(a) A party or non-party disclosing or producing a document may designate it as confidential if the party or non-party contends that it contains confidential or proprietary information.
(b) A party or non-party may designate a document as confidential by conspicuously marking each page with the word "confidential."
(c) Deposition testimony may be designated as ...

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