SUSNJAR v. AMAZON LOGISTICS INC et al

Filing 8

PROTECTIVE ORDER Ordered by US DISTRICT JUDGE TILMAN E SELF, III on 3/11/2025. (vs)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
MILORAD SUSNJAR,
Plaintiff,
CIVIL ACTION NUMBER:
5:25-cv-00069-TES

vs.
FOUR S LOGISTICS, INC. &
AMAZON LOGISTICS, INC.,
Defendants.

CONFIDENTIALITY AGREEMENT AND STIPULATED
PROTECTIVE ORDER
WHEREAS O.C.G.A. § 9-11-26 provides for the issuance of a protective
order limiting the disclosure of confidential information in appropriate
circumstances, the Court hereby ORDERS the entry of this Confidentiality
Agreement and Stipulated Protective Order in the above-captioned action.
1.

Scope.

This Confidentiality Agreement and Stipulated

Protective Order (hereinafter “Protective Order”) shall govern the production and
use of all documents, information, data, material, studies, recordings, testimony,
and/or other items (hereinafter collectively “documents”) produced by Amazon
Logistics, Inc. (“Defendant”), through their respective counsel, in response to
discovery requests served by the other parties to this action or utilized and/or
referenced during depositions or other proceedings in this action, which

Defendants and/or their respective counsel designate as “CONFIDENTIAL” or
“ATTORNEYS’ EYES ONLY.” The protections conferred by this Protective
Order cover not only documents (as defined above), but also (1) any “Confidential
Information” and “Attorneys’ Eyes Only Information” copied or extracted from
documents; (2) all copies, excerpts, summaries, or compilations of “Confidential
Information” and “Attorneys’ Eyes Only Information”; and (3) any testimony,
conversations, or presentations by parties or their Counsel that might reveal
“Confidential Information” and “Attorneys’ Eyes Only Information.”
2.

Dissemination/Disclosure.

Any person or entity subject to this

Protective Order, as set forth below, shall not disseminate or disclose documents
designated as “CONFIDENTIAL,” or “ATTORNEYS’ EYES ONLY,” or the
information contained therein, except in furtherance of limited purposes directly
related to the prosecution of claims or defenses in this action as permitted by this
Protective Order. As used in this Protective Order, the term “disseminate” shall
include, but not be limited to, speaking about or paraphrasing the contents of;
posting through electronic means, the internet, or social media, the contents of; and
copying, photographing, scanning, streaming, videotaping, transcribing, retyping,
reproducing, or reprinting by any means whatsoever, any documents designated as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” The parties and counsel

shall be subject to all restrictions on dissemination and disclosure set forth in this
Protective Order.
3.

Form and Timing of Designation. Confidential documents shall be

so designated by placing or affixing the word “CONFIDENTIAL” on the
document in a manner which will not interfere with the legibility of the document,
and which will permit complete removal of the “CONFIDENTIAL” designation.
“Attorneys’ Eyes Only” documents shall be so designated by placing or affixing
the words “ATTORNEYS’ EYES ONLY” on the document in a manner which
will not interfere with the legibility of the document, and which will permit
complete removal of the “ATTORNEYS’ EYES ONLY” designation. Documents
shall be designated “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” prior
to, or contemporaneously with, the production or disclosure of the documents.
Inadvertent or unintentional production of documents without prior designation as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” shall not be deemed a
waiver, in whole or in part, of the right to designate documents as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” as otherwise allowed by
this Protective Order.
4.

Documents Which May be Designated Confidential. A party may

designate documents as “CONFIDENTIAL” but only after review of the

documents and certification by an attorney1 who has, in good faith, determined that
the documents contain “Confidential Information.” “Confidential Information” as
used in this Protective Order shall mean information which falls within one or
more of the following categories:
a. Protected from disclosure by statute;
b. Sensitive personal information;
c. Personal Identifying Information;
d. Trade secrets;
e. Research, technical, commercial, or financial information that the
producing party has maintained as confidential;
f. Non-public information maintained by a third party as confidential that
the producing party receives, obtains, or is provided access to that the
producing party has maintained as confidential;
g. Medical information concerning any individual;
h. Tax returns (including attached schedules and forms) and tax forms
including, but not limited to, W-2 forms and 1099 forms; or

1

The attorney who reviews the documents and certifies them to be “CONFIDENTIAL” must be admitted
to the Bar of at least one state but need not be admitted to practice in Georgia and need not apply for pro
hac vice admission. By signing the certification, counsel submits to the jurisdiction of this court in regard
to the certification.

i. Personnel or employment records of a person who is not a party to the
action.
The certification shall be made concurrently with the disclosure of the
documents, using the form attached hereto at Attachment A which shall be
executed in accordance with the standards of the Georgia Civil Practice Act.
Information or documents which are available in the public sector may not be
designated as “CONFIDENTIAL.”
5.

Documents Which May be Designated Attorneys’ Eyes Only. A

party may designate documents as “ATTORNEYS’ EYES ONLY” but only after
review of the documents and certification by an attorney2 who has, in good faith,
determined that the documents contain “Attorneys’ Eyes Only Information.”
“Attorneys’ Eyes Only Information” is extremely sensitive “Confidential
Information,” disclosure of which to another party or nonparty would create a
substantial risk of serious harm to the business or competitive position of the
designating party that could not be avoided by less restrictive means. “Attorneys’
Eyes Only Information” as used in this Protective Order shall mean information
that falls within one or more of the following categories:

2

The attorney who reviews the documents and certifies them to be “ATTORNEYS’ EYES ONLY” must
be admitted to the Bar of at least one state but need not be admitted to practice in Georgia and need not
apply for pro hac vice admission. By signing the certification, counsel submits to the jurisdiction of this
court in regard to the certification.

a. Information consisting of, reflecting, or representing computer code and
associated comments and revision histories, formulas, engineering
specifications, or schematics that define or otherwise describe in detail
the algorithms or structure of software or hardware designs;
b. Information consisting of, reflecting, or representing raw data generation,
collection, receipt, access, processes, analyses, and storage;
c. Information consisting of, reflecting, or representing analytics or metrics
derivative of raw data;
d. Business, enterprise, or operational data architecture, data modeling, data
infrastructure, data management, data analytics, or data metrics, and any
associated proprietary systems, software, networks, platforms, or
databases;
e. Sensitive business information, including highly sensitive financial or
marketing information;
f. Competitive technical information, including technical analyses of
products or services;
g. Competitive business information, including non-public financial and
marketing analyses, comparisons of products or services, and strategic
product or service expansion plans;

h. Vendor or business partner relationships or documents that fall within
one or more of the aforementioned categories defined in this Paragraph
4, sub-paragraphs (a) - (g); or
i. Any other commercially sensitive information the disclosure of which to
non-qualified persons subject to this Protective Order the producing
party reasonably and in good faith believes would likely cause harm.
The certification shall be made concurrently with the disclosure of the
documents, using the form attached hereto at Attachment A which shall be
executed in accordance with the standards of the Georgia Civil Practice Act.
Information or documents which are available in the public sector may not be
designated as “ATTORNEYS’ EYES ONLY.”
6.

Depositions.

Portions

of

depositions

shall

be

deemed

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” if designated as such
when the deposition is taken. Such designation shall be specific as to the portions
to be protected. The portions of the transcripts of all such testimony shall be
designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” and shall be
labeled with the appropriate notation by the court reporter/stenographer. To the
extent documents designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES
ONLY” are used in the taking of depositions, same shall remain subject to the
provisions of this Protective Order, unless the Court expressly rules otherwise. If

any document designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES
ONLY” pursuant to this Protective Order is used during the course of a deposition
in this lawsuit, that portion of the deposition record referencing such document
shall be labeled with the appropriate “CONFIDENTIAL” or “ATTORNEYS’
EYES ONLY” designation. The court reporter/stenographer also shall clearly and
conspicuously mark the front page of any transcript which contains references to
Confidential Information or Attorneys’ Eyes Only Information with the respective
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” designation.

If

Confidential Information or Attorneys’ Eyes Only Information is to be disclosed
at a deposition, the producing party shall have the right to exclude from
attendance, during the time in which the Confidential Information or Attorneys’
Eyes Only Information is to be discussed, any persons not bound by this
Protective Order.
“Confidential Information” or “Attorneys’ Eyes Only Information”
disclosed at a deposition may also be designated as such by notifying all parties in
writing not later than thirty (30) days after receipt of the transcript of the specific
pages and lines of the transcript that should be designated as “CONFIDENTIAL”
or “ATTORNEYS’ EYES ONLY.” Each party shall attach a copy of each such
written notice to the face of the transcript and each copy thereof in that party’s
possession, custody, or control. All deposition transcripts shall be treated as

“ATTORNEYS’ EYES ONLY” for a period of 30 days after initial receipt of the
transcript.
7.

Protection of Confidential and Attorneys’ Eyes Only Material.

a.

General Protections. Documents designated “CONFIDENTIAL” or

“ATTORNEYS’ EYES ONLY” under this Protective Order shall not be
used, disclosed, or disseminated by the parties or counsel for the parties or
any other persons identified below (¶ 7.b.) for any purposes whatsoever
other than preparing for and conducting the litigation in which the
documents were disclosed (including any appeal of that litigation).
b.

Limited Third-Party Disclosures of Confidential Material. The

parties and counsel for the parties shall not disclose or permit the disclosure
of any documents designated “CONFIDENTIAL” under the terms of this
Protective Order to any other person or entity except for “qualified persons”
as set forth in subparagraphs (1) through (5) below, and then only after the
person to whom disclosure is to be made has executed an acknowledgment
(in the form set forth at Attachment B hereto), that he or she has read and
understands the terms of this Protective Order and is bound by it. Subject to
these requirements, the following categories of persons may be allowed to
review documents which have been designated “CONFIDENTIAL”
pursuant to this Protective Order:

(1)

counsel and employees of counsel for the parties who have

responsibility for the preparation and trial of the lawsuit;
(2)

parties and employees of a party to this Protective Order but

only to the extent counsel shall certify that the specifically named
individual party or employee’s assistance is necessary to the conduct
of the litigation in which the information is disclosed3;
(3)

court reporters engaged for depositions and those persons, if

any, specifically engaged for the limited purpose of making
photocopies of documents;
(4)

consultants, investigators, or experts (hereinafter referred to

collectively as “experts”) employed by the parties or counsel for the
parties to assist in the preparation and trial of the lawsuit; and
(5)

other persons only upon consent of the producing party or upon

order of the court and on such conditions as are agreed to or ordered.
c.

Limited Third-Party Disclosures of Attorneys’ Eyes Only

Material. The parties and counsel for the parties shall not disclose or permit
the disclosure of any documents designated “ATTORNEYS’ EYES ONLY”
under the terms of this Protective Order to any other person or entity except

3

At or prior to the time such party or employee completes his or her acknowledgment of review of this
Protective Order and agreement to be bound by it (Attachment B hereto), counsel shall complete a
certification in the form shown at Attachment C hereto. Counsel shall retain the certification together
with the form signed by the party or employee.

for “qualified persons” as set forth in subparagraphs (1) through (4) below,
and then only after the person to whom disclosure is to be made has
executed an acknowledgment (in the form set forth at Attachment B hereto),
that he or she has read and understands the terms of this Protective Order
and is bound by it. Subject to these requirements, the following categories
of persons may be allowed to review documents which have been designated
“ATTORNEYS’ EYES ONLY” pursuant to this Protective Order:
(1)

counsel and employees of counsel for the parties who have

responsibility for the preparation and trial of the lawsuit;
(2)

court reporters engaged for depositions and those persons, if

any, specifically engaged for the limited purpose of making
photocopies of documents;
(3)

consultants or experts (hereinafter referred to collectively as

“experts”) employed by the parties or counsel for the parties to assist
in the preparation and trial of the lawsuit; and
(4)

other witnesses only upon consent of the producing party or

upon order of the court and on such conditions as are agreed to or
ordered.
d.

Control of Documents.

Counsel for the parties shall take

reasonable efforts to prevent unauthorized disclosure of documents

designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” or
dissemination of the Confidential or Attorneys’ Eyes Only information
contained therein, pursuant to the terms of this Protective Order. Counsel
shall maintain a record of those persons, including employees of counsel,
who have reviewed or been given access to the documents along with the
originals of the forms signed by those persons acknowledging their
obligations under this Protective Order. If a receiving party learns of any
unauthorized disclosure of “Confidential Information” or “Attorneys’ Eyes
Only Information,” the party shall immediately upon learning of such
disclosure inform the producing party of all pertinent facts relating to such
disclosure and shall make all reasonable efforts to prevent disclosure by each
unauthorized person who received such information.
e.

Unintentional Disclosures.

Documents unintentionally

produced without designation as “CONFIDENTIAL” or “ATTORNEYS’
EYES ONLY” may be later designated and shall be treated as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” from the date
written notice of the designation is provided to the receiving party.
f.

Copies.

All copies, duplicates, extracts, summaries or

descriptions (hereinafter referred to collectively as “copies”), of documents
designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” under this

Protective Order or any portion of such a document, shall be immediately affixed
with the designation “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” if the
word or words do not already appear on the copy. All such copies shall be
afforded the full protection of this Protective Order.
8.

Filing of Confidential and Attorneys’ Eyes Only Materials. In the

event a party seeks to file any material that is subject to protection under this
Protective Order with the court, that party shall take appropriate action to ensure
that the documents receive proper protection from public disclosure including: (1)
filing a redacted document with the consent of the party who designated the
document as confidential; (2) where appropriate (e.g. in relation to discovery and
evidentiary motions), submitting the documents solely for in camera review; or (3)
where the preceding measures are not adequate, seeking permission to file the
document under seal in accordance with the Georgia Civil Practice Act, or such
other rule or procedure as may apply in the relevant jurisdiction.
extraordinary

circumstances

making

prior

consultation

Absent

impractical

or

inappropriate, the party seeking to submit the document to the court shall first
consult with counsel for the party who designated the document as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” to determine if some
measure less restrictive than filing the document under seal may serve to provide
adequate protection. This duty exists irrespective of the duty to consult on the

underlying motion. Nothing in this Protective Order shall be construed as a prior
directive to the Clerk of Court to allow any document be filed under seal. The
parties understand that documents may be filed under seal only with the permission
of the court after proper motion in accordance with proper procedure as indicated
above.
9.

Greater Protection of Specific Documents. No party may withhold

information from discovery on the ground that it requires protection greater than
that afforded by this Protective Order unless the party moves for an order
providing such special protection.
10.

Challenges to Designation as Confidential or Attorneys’ Eyes

Only. Any “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” designation is
subject to challenge. The following procedures shall apply to any such challenge:
a.

The burden of proving the necessity of a “CONFIDENTIAL” or

“ATTORNEYS’ EYES ONLY”

designation remains with the party

asserting confidentiality or the need for “Attorneys’ Eyes Only” levels of
protection to extremely sensitive “Confidential Information.”
b.

A party who contends that documents designated “CONFIDENTIAL”

or “ATTORNEYS’ EYES ONLY” are not entitled to confidential treatment
shall give written notice to the party who affixed the designation of the
specific basis for the challenge. The party who so designated the documents

shall have fifteen (15) days from service of the written notice to determine if
the dispute can be resolved without judicial intervention and, if not, to move
for an order confirming the Confidential or Attorneys’ Eyes Only
designation.
c.

Notwithstanding any challenge to the designation of documents as

confidential, all documents previously designated “CONFIDENTIAL” or
“ATTORNEYS’ EYES ONLY” shall continue to be treated as subject to the
full protections of this Protective Order until one of the following occurs:
(1)

the

party

who

claims

that

the

documents

are

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” withdraws
such designation in writing;
(2)

the

party

who

claims

that

the

documents

are

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” fails to move
timely for an order designating the documents as “CONFIDENTIAL”
or “ATTORNEYS’ EYES ONLY” as set forth in paragraph 9.b.
above; or
(3)

the court rules that the documents should no longer be

designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES
ONLY.”

d.

Challenges to “CONFIDENTIAL” or “ATTORNEYS’ EYES

ONLY” designations of documents may be made at any time and are not
waived by the failure to raise the challenge at the time of initial disclosure or
designation.
11.

Documents Produced for Inspection Prior to Designation. In the

event documents are produced for inspection prior to designation, the documents
shall be treated as “ATTORNEYS’ EYES ONLY” during inspection. At the time
of

copying

for

the

inspecting

parties,

shall

be

marked

prominently

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” by the producing party.
12.

Treatment on Conclusion of Litigation.

a.

Protective Order Remains in Effect.

Protective

Order

restricting

the

use

of

All provisions of this
documents

designated

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” shall continue to be
binding after the conclusion of the litigation unless otherwise agreed or
ordered.
b.

Return of CONFIDENTIAL and ATTORNEYS’ EYES ONLY

Documents. Within thirty (30) days after the conclusion of the litigation,
including

conclusion

of

any

appeal,

all

documents

treated

as

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” under this
Protective Order, including copies as defined above (¶7.e.) shall be returned

to the producing party and deleted from all electronic devices unless: (1) the
document has been entered as evidence or filed (unless introduced or filed
under seal); (2) the parties stipulate to destruction in lieu of return; or (3) as
to documents containing the notations, summations, or other mental
impressions of the receiving party, that party elects destruction.
Notwithstanding the above requirements to return or destroy documents,
counsel may retain attorney work product including an index which refers or
relates to information designated “CONFIDENTIAL” or “ATTORNEYS’
EYES ONLY” so long as that work product does not duplicate verbatim
substantial portions of the text of “CONFIDENTIAL” or “ATTORNEYS’
EYES ONLY” documents.

This work product continues to be

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” under the terms of
this Protective Order. An attorney may use his or her work product in a
subsequent litigation provided that its use does not disclose the
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY”.
13.

Protective Order Subject to Modification. This Protective Order

shall be subject to modification on motion of any party or any other person who
may show an adequate interest in the matter to intervene for purposes of addressing
the scope and terms of this Protective Order. This Protective Order shall not,

however, be modified until the parties shall have been given notice and an
opportunity to be heard on the proposed modification.
14.

No Judicial Determination. This Protective Order is entered based

on the representations and agreements of the parties and for the purpose of
facilitating discovery. Nothing herein shall be construed or presented as a judicial
determination that any specific document or item of information designated as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” by counsel is subject to
protection under the Georgia Civil Practice Act or otherwise until such time as a
document-specific ruling shall have been made.
15.

Persons Bound. This Protective Order shall take effect when entered

and shall be binding upon: (1) counsel who signed below and their respective law
firms; and (2) their respective clients.
SO ORDERED this ____
2025.
11 day of _______________,
March
s/Tilman E. Self, III
___________________________________
The Honorable Tilman E. Self, III
Judge, Federal District Court, Middle District of
Georgia, Macon Division
Prepared By:
Kathryn T. Gathy, Esq.
Georgia Bar No. 894772
[e-mail]
Counsel for Defendant Amazon Logistics, Inc.

Consents on Following Page

Consented By:
Chloe B. Thompson, Esq.
Georgia Bar No. 729103
Phillip A. Pendergrass, Esq.
Georgia Bar No. 529699
[e-mail]
[e-mail]
Counsel for Plaintiff
David N. Nelson, Esq.
Georgia Bar No. 537760
Liza McDaniel
Georgia Bar No. 993877
[e-mail]
[e-mail]
Counsel for Four S Logistics, Inc.

ATTACHMENT A
CERTIFICATION BY COUNSEL OF DESIGNATION
OF INFORMATION AS “CONFIDENTIAL” OR “ATTORNEYS’ EYES
ONLY”
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
MILORAD SUSNJAR,
Plaintiff,
CIVIL ACTION NUMBER:
5:25-cv-00069-TES

vs.
FOUR S LOGISTICS, INC. &
AMAZON LOGISTICS, INC.,
Defendants.

Documents produced herewith [whose bates numbers are listed below (or)
which are listed on the attached index] have been marked as
“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” subject to the Stipulated
Confidentiality and Protective Order entered in this action which Protective Order
is dated ____________.
By signing below, I am certifying that I have personally reviewed the
marked documents and believe, based on that review, that they are properly subject
to protection under the terms of Paragraphs 3 or 4 of the Confidentiality
Agreement and Stipulated Protective Order.
Check and complete one of the two options below.
?
I am a member of the Georgia Bar. My Bar number is _________.
?

I am not a member of the Georgia Bar but am admitted to the Bar of
one or more states. The state in which I conduct the majority of my
practice is ______________ where my Bar number is __________. I
understand that by completing this certification I am submitting to the

jurisdiction of the Federal District Court, Middle District of Georgia
as to any matter relating to this certification.
Date:
Signature of Counsel

Printed Name of Counsel

ATTACHMENT B
ACKNOWLEDGMENT OF UNDERSTANDING AND
AGREEMENT TO BE BOUND
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
MILORAD SUSNJAR,
Plaintiff,
CIVIL ACTION NUMBER:
5:25-cv-00069-TES

vs.
FOUR S LOGISTICS, INC. &
AMAZON LOGISTICS, INC.,
Defendants.

The undersigned hereby acknowledges that he or she has read the Confidentiality
Agreement and Stipulated Protective Order dated ___________, in the abovecaptioned action, understands the terms thereof, and agrees to be bound by such
terms. The undersigned submits to the jurisdiction of the Federal District Court,
Middle District of Georgia in matters relating to the Stipulated Confidentiality and
Protective Order and understands that the terms of said Protective Order obligate
him/her to use discovery materials designated as “CONFIDENTIAL” or
“ATTORNEYS’ EYES ONLY” solely for the purposes of the above-captioned
action, and not to disclose any such “CONFIDENTIAL” or “ATTORNEYS’
EYES ONLY” documents or information to any other person, firm, or concern.
The undersigned acknowledges that violation of the Confidentiality
Agreement and Stipulated Protective Order may result in penalties for contempt of
court.
Name:

Job Title:

Employer:

Business Address:

Date:

Signature

ATTACHMENT C
CERTIFICATION OF COUNSEL OF NEED
FOR ASSISTANCE OF PARTY/EMPLOYEE
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
MACON DIVISION
MILORAD SUSNJAR,
PLAINTIFF,
CIVIL ACTION NUMBER:
5:25-CV-00069-TES

VS.
FOUR S LOGISTICS, INC. &
AMAZON LOGISTICS, INC.,
DEFENDANTS.

PURSUANT
TO
THE
CONFIDENTIALITY
AGREEMENT
AND
STIPULATED PROTECTIVE ORDER ENTERED IN THIS ACTION, MOST
PARTICULARLY THE PROVISIONS OF PARAGRAPH 7.B.2., I CERTIFY
THAT THE ASSISTANCE OF ________________________________________
IS REASONABLY NECESSARY TO THE CONDUCT OF THIS LITIGATION
AND THAT THIS ASSISTANCE REQUIRES THE DISCLOSURE TO THIS
INDIVIDUAL OF INFORMATION WHICH HAS BEEN DESIGNATED AS
“CONFIDENTIAL.”
I HAVE EXPLAINED THE TERMS OF THE CONFIDENTIALITY AND
STIPULATED PROTECTIVE ORDER TO THE INDIVIDUAL NAMED
ABOVE AND WILL OBTAIN HIS OR HER SIGNATURE ON AN
“ACKNOWLEDGMENT OF UNDERSTANDING AND AGREEMENT TO BE
BOUND” PRIOR TO RELEASING ANY “CONFIDENTIAL” DOCUMENTS
TO THE NAMED INDIVIDUAL AND I WILL RELEASE ONLY SUCH
CONFIDENTIAL DOCUMENTS AS ARE REASONABLY NECESSARY TO
THE CONDUCT OF THE LITIGATION.

THE INDIVIDUAL NAMED ABOVE IS:
?

A NAMED PARTY;

?

AN EMPLOYEE OF NAMED PARTY _______________________.
THIS EMPLOYEE’S JOB TITLE IS
____________________________AND WORK ADDRESS IS
_______________________________________________________.

DATE:
COUNSEL SIGNATURE