Opinion
7:21-cv-73-HL
08-16-2021
MEXICAN AMERICAN LEGAL DEFENSE AND EDUCATIONAL FUND Tanya G. Pellegrini Belinda Escobosa Helzer (CA Bar No. 214178)* Tanya G. Pellegrini (CA Bar No. 285186)* Juan Rodriguez (CA Bar No. 282081)* ESHMAN BEGNAUD, LLC Mark Begnaud Georgia Bar No. 217641 Michael J. Eshman Georgia Bar No. 365497 *Admitted pro hac vice Attorneys for Plaintiff P.R. PETER D. LEARY ACTING UNITED STATES ATTORNEY AMELIA G. HELMICK Assistant United States Attorney Georgia Bar No. 142673 BOWEN REICHERT SHOEMAKER Assistant United States Attorney Georgia Bar No. 222443 U.S. Attorney's Office Middle District of Georgia Attorneys for Defendant United States of America
MEXICAN AMERICAN LEGAL DEFENSE AND EDUCATIONAL FUND Tanya G. Pellegrini Belinda Escobosa Helzer (CA Bar No. 214178)* Tanya G. Pellegrini (CA Bar No. 285186)* Juan Rodriguez (CA Bar No. 282081)*
ESHMAN BEGNAUD, LLC Mark Begnaud Georgia Bar No. 217641 Michael J. Eshman Georgia Bar No. 365497 *Admitted pro hac vice Attorneys for Plaintiff P.R.
PETER D. LEARY ACTING UNITED STATES ATTORNEY AMELIA G. HELMICK Assistant United States Attorney Georgia Bar No. 142673
BOWEN REICHERT SHOEMAKER Assistant United States Attorney Georgia Bar No. 222443 U.S. Attorney's Office Middle District of Georgia Attorneys for Defendant United States of AmericaPROTECTIVE ORDER REGARDING IDENTITY OF P.R.
Honorable Hugh Lawson, Senior United States District Court Judge
Pursuant to Federal Rule of Civil Procedure 26(c), the following confidentiality and protective order regarding the identity of Plaintiff P.R. (“Identity Protective Order”) is entered solely to govern the dissemination of information related to P.R.'s true identity.
1. Information and Evidence Protected by this Identity Protective Order
The information governed by this Identity Protective Order includes only the information, documents, and other evidence necessary to verify the identity of Plaintiff P.R., who is proceeding in this case under a pseudonym. This Identity Protective Order is not intended to govern or address information or documents that may otherwise be subject to discovery should discovery commence later in this case.
2. Persons Qualified to Receive Information Subject to Identity Protective Order
The information and evidence addressed in this Identity Protective Order may be disclosed the following individuals:
a) the parties, if natural persons;
b) if the party is an entity, officers or employees of the party; and
c) retained counsel for the parties in this litigation and their respective staff.
The information and evidence addressed in this Identity Protective Order may be disclosed to additional persons subject to the disposition of any motions to dismiss that may be filed. If additional disclosure becomes necessary following initial motions, that disclosure will be addressed in a supplemental protective order that will be negotiated prior to the commencement of the discovery period.
3. Required Disclosure of Confidential Information
The information and evidence subject to this Identity Protective Order shall not be disclosed or made available to persons other than Qualified Persons except as necessary to comply with applicable law or court order. If any party, or that party's counsel, is required by law or court order to disclose the information or evidence to any person or entity not identified in Paragraph 2, the party or the party's counsel who is being required to disclose it shall notify counsel as far in advance of disclosure as is reasonably possible (not less than two weeks, in the absence of good cause), so that the producing party may object and seek further protection as necessary. Any objection to production must be made within five days of such notification.
4. Use of Confidential Information
All information and evidence covered by this Identity Protective Order that is provided by any party or nonparty in the course of this litigation shall be used solely for the purpose of this litigation, including any appeal, and shall not be disclosed except in accordance with the terms herein.
5. Modifications
The parties may, by stipulation, provide for exceptions to this Protective Order and any party may seek an order of this court modifying this Protective Order.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Respectfully submitted, Dated: July 27, 2021
PURSUANT TO STIPULATION, IT IS SO ORDERED.