Securities and Exchange Commission v. Medient Studios, Inc. et al

Filing 18

ORDER MEMORIALIZING PARTIES' AGREEMENT REGARDING INADVERTENT PRODUCTION OF PRIVILEGED DOCUMENTS. Signed by Magistrate Judge G. R. Smith on 2/6/17. (jlm)

Case 4:16-cv-00253-WTM-GRS Document 16-1 Filed 01/20/17 Page lot 3

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF GEORGIA

SAVANNAH DIVISION

0

SECURITIES AND EXCHANGE

COMMISSION,
Plaintiff,
Case No. 4:16-cv- 00253

V.

WTM-GRS

MEDIENT STUDIOS,INC.,FONU2,
INC., MANU KUMARAN,JOEL A.
"JAKE" SHAPIRO,and ROGER
MIGUEL,
Defendants.

fPROPOSEDl ORDER MEMORIALIZING PARTIES' AGREEMENT REGARDING
INADVERTENT PRODUCTION OF PRIVILEGED DOCUMENTS

This matter is before the Court at the request ofthe parties, who seek to have their
agreement regarding the treatment of inadvertently produced privileged documents entered in the
record as a Court Order. As the parties have so agreed, and the Court finds the terms to be
acceptable, the Court hereby incorporates the agreement into this Order as follows:
1)

All documents produced by the parties shall be considered as produced pursuant to
this agreement regarding the inadvertent production of privileged documents
("Agreement").

2)

By producing documents pursuant to this Agreement, the parties do not intend to
waive, and are not waiving, any claim of privilege or work product protection
("Privilege")that is applicable to such documents before their production, except as
provided in paragraphs 3 and 4 below. The parties agree not to assert that any
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