Morgan v. V2X, Inc.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Magistrate Judge Maritza Dominguez Braswell
Civil Action No. 25–cv–01991–SKC–MDB
ARCHIE MORGAN,
Plaintiff,
v.
V2X, Inc.,
Defendant.
ORDER
Before the Court is Defendant’s Motion to Amend the Stipulated Protective Order,
seeking to add language that specifically addresses the use of modern artificial intelligence tools
(“AI”), and asking the Court to compel disclosure of Plaintiff’s AI. ([“Motion”], Doc. No. 52).
Plaintiff opposes, in part. (Doc. Nos. 58, 59.) Defendant has replied. (Doc. No. 60.) After
considering the Motion, applicable law, and facts and circumstances of this case, the Motion is
GRANTED, in part.
SUMMARY FOR PRO SE PLAINTIFF
The Court is granting Defendant’s Motion, in part. Federal Rule of Civil Procedure
26(b)(3) can protect your mental impressions and litigation preparation materials, but you must
disclose the name of any AI tool you used in connection with Confidential Information. This is
because you have not demonstrated that identifying the tool itself will reveal your mental
impressions or legal strategy, and Defendant needs that information to assess whether
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Confidential Information was compromised. The Court is also amending the Protective Order to
address AI use. The practical effect is that you may not upload, input, or submit Confidential
Information into any mainstream AI tool like standard ChatGPT, Claude, Gemini, or similar
platforms.
BACKGROUND
This is an employment discrimination case where Plaintiff, a self-described “qualified
Black American manager,” claims he was subjected to a hostile work environment and
eventually “terminated based on his race and national origin and in retaliation for protected
activities, including opposing sexual harassment and engaging in protected whistleblowing
activity.” (Doc. No. 35 at 2-3.)
Defendant says Plaintiff was discharged for “legitimate and non-discriminatory, non-
retaliatory reasons,” after “a workplace complaint was lodged against [Plaintiff],” and Defendant
“conducted a thorough investigation, including interviewing and/or taking the statements of more
than 30 witnesses.” (Id. at 3-4.)
The Dispute
Defendant brought the instant Motion shortly after Plaintiff moved to compel an
insurance policy. ([“Plaintiff’s MTC”], Doc. No. 48.) Plaintiff’s MTC claimed that Defendant
was refusing to produce a copy of the insurance policy, as “leverage to force Plaintiff’s consent
to a modified Protective Order.” (Doc. No. 48 at 2.) Specifically, Plaintiff claimed that
Defendant sought disclosure of Plaintiff’s AI tool, and restrictions on Plaintiff’s AI use, before it
would provide the insurance policy to Plaintiff. (Id.) Plaintiff characterized this as “holding a
four-month overdue disclosure ‘hostage’ to force an amendment to a Protective Order,” in a way
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that “creates an unfair ‘technological gap’ by barring a pro se litigant from using modern
analytical aids while Defendant’s firm maintains its own proprietary AI and cloud-based
systems.” (Id. at 3.)
The Court struck Plaintiff’s MTC for failure to follow the Court’s discovery dispute
procedures but set a discovery hearing to address Plaintiff’s concerns. (Doc. No. 51.) However,
the morning of the discovery hearing, Defendant’s counsel emailed Chambers saying:
I am writing on behalf of Defendant, V2X, Inc. (“V2X”), with regarding to
the discovery conference set in the above-referenced case for 12:00 p.m.
MT today, March 3, 2026, in connection with Plaintiff Archie Morgan’s
motion to compel. See ECF Nos. 48, 51. Mr. Morgan is cc’ed on this
correspondence and agrees to the relief requested herein.
Per 	the 	Court’s 	direction, 	the 	parties 	meaningfully 	conferred 	via
videoconference on February 26, 2026. Following that conferral, the
parties resolved their discovery dispute regarding Mr. Morgan’s motion to
compel discovery, and V2X has produced to Plaintiff the requested
document underlying his motion. Accordingly, the parties jointly request
that the Court vacate the discovery conference set for later today.
Accordingly, the Court vacated the hearing.
Upon careful review of the instant Motion and related materials, the Court finds it is
based on some of the same disputes underlying Plaintiff’s now stricken MTC. Both parties
appear to be using AI in connection with their litigation work, but they disagree on how AI
should or should not be used in connection with Confidential Information as defined in the
current Protective Order. (Doc. No. 30.)
The Current Protective Order
The current Protective Order allows the parties to designate information “Confidential”
when it “is confidential and implicates the privacy or business interests of the parties, including
but not limited to: medical and personal financial information, private personnel information,
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trade secrets, and other proprietary business information.” (Doc. No. 30 at 1.) The Protective
Order provides that all Confidential Information “shall not, without the consent of the
designating party or further Order of the Court, be disclosed,” except under limited, specifically
enumerated, circumstances. (Id. at 2.)
Defendant’s Motion & Plaintiff’s Response
Although Defendant’s Motion is styled as one to amend the current Protective Order, it
requests two forms of relief. First, Defendant asks the Court to enter an amended protective order
with new language that specifically addresses its AI-related concerns. Second, Defendant asks
the Court compel Plaintiff to “disclose the identity of the AI tool [Plaintiff] is utilizing in this
case so that [Defendant] can determine whether it does, in fact, have appropriate safeguards in
place regarding [Defendant’s] confidential information.” (Doc. No. 52 at 5.)
For his part, Plaintiff does not oppose amending the current Protective Order, but he
offers competing language. Plaintiff does however oppose disclosure of his AI, saying “[t]he
specific software, research platforms, and analytical tools chosen by a litigant to review
discovery, synthesize information, and prepare for trial fall squarely under the Work-Product
Doctrine, codified in Federal Rule of Civil Procedure 26(b)(3).” (Doc. No. 58 at 2.)
ANALYSIS
AI is forcing litigants and courts to confront difficult questions about how and to what
extent longstanding protections will apply when parties use AI to assist them in the litigation
process. In particular, courts are beginning to wrestle with practical questions surrounding
confidentiality, work product, and privilege. This dispute raises two such questions: (1) to what
extent will work product protections apply to a pro se litigant’s use of AI, and (2) to what extent
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should a protective order expressly restrict the use of AI? The Court addresses each question in
turn.
I. 	Do work product protections apply to pro se Plaintiff’s use of AI, and in particular,
to his tool selection?
Defendant seeks disclosure of Plaintiff’s AI so it can “verify it has appropriate
confidentiality restrictions.” (Doc. No. 60 at 3; see also Doc. No. 52 at 5.) Plaintiff resists, citing
Federal Rule of Civil Procedure 26(b)(3). (Doc. No. 58 at 2.) The Court begins by considering
the applicability of the Rule, then it moves on to consider the scope of its protections under these
facts and circumstances.
A. Applicability of Rule 26(b)(3)
Federal Rule of Civil Procedure 26(b)(3)(A) protects “documents and tangible things that
are prepared in anticipation of litigation or for trial by or for another party or its representative.”
Mental impressions, conclusions, opinions, and legal theories, are contents that may be
embedded in such documents and tangible materials. See Rule 26(b)(3)(B) (referencing Rule
26(b)(3)(A) and recognizing that “those materials” may include mental impressions, conclusions,
opinions, and legal theories). Rule 26(b)(3)(B) adds another layer of protection to mental
impressions and opinions when they come from “a party’s attorney or other representative…”
This heightened protection is consistent with the doctrine’s origins in Hickman v. Taylor, 329
U.S. 495 (1947).
The Tenth Circuit has not weighed in on the applicability of Rule 26(b)(3) to pro se
litigants, but the plain language broadly refers to things prepared in anticipation of litigation by
any party, language that would “seem to include material created by a party before retaining a
lawyer as well as a party who never actually hires an attorney.” Jennifer A. Gundlach & Zeus
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Smith, Expanding the Federal Work Product Doctrine to Unrepresented Litigants, 30 GEO. J. ON
P OVERTY L. & P OL’Y 53, 62 (2022) (hereinafter “Gundlach & Smith”). This reading is reinforced
by the Rule’s history. See generally id. Prior to the 1970 amendments, some courts had declined
to protect work product prepared by anyone other than an attorney, but the Advisory
Committee’s amendments were specifically designed to extend protection beyond attorneys’
work product to materials prepared by or for a party. Id. at 61–62. Since then, courts routinely
interpret the Rule to apply not just to attorney work product, but to a pro se litigant’s work
product as well. See Carbajal v. St. Anthony Cent. Hosp., 2014 WL 2459713, at *2 (D. Colo.
June 2, 2014) (assuming without deciding that the work product protection in Rule 26(b)(3)
applies to a pro se litigant); Anderson v. Furst, 2019 WL 2284731, at *4 (E.D. Mich. May 29,
2019) (stating, “a pro se litigant[ ] has a right to assert work product protection” under Rule
26(b)(3)); Yates v. Cobb Cnty. Sch. Dist., 2016 WL 9444452, at *2 (N.D. Ga. Aug. 4, 2016)
(finding persuasive authority indicating pro se plaintiffs can assert work product protections
under Rule 26(b)(3)).
Moreover, courts have broadly interpreted the rule to protect not just litigation
preparation materials, but also the mental impressions, opinions, and theories of parties. See,
e.g., Moore v. Tri-City Hosp. Auth., 118 F.R.D. 646, 649–50 (N.D. Ga. 1988) (finding work
product protection applied to plaintiff’s diary); Ortega v. New Mexico Legal Aid, Inc., 2019 WL
5864784, at *3 (D.N.M. Nov. 8, 2019) (finding pro se plaintiff’s mental impressions, opinions
and legal theories set forth in diaries, agendas, notebooks, and more, to be protected work
product); Carrier-Tal v. McHugh, 2016 WL 9185306 (E.D. Va. Feb. 3, 2016) (overruling
objections to a magistrate judge’s order that found work product protections applied to a pro se
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plaintiff’s mental thoughts, impressions, and litigation strategy); Moore v. Kingsbrook Jewish
Med. Ctr., 2012 WL 1078000, at *8 (E.D.N.Y. Mar. 30, 2012) (overruling objections to
magistrate judge order that found a pro se litigant’s personal notes reflected her mental
impressions of the deposition and the litigation and were therefore protected work product).
Thus, while only attorneys and “other representatives” receive additional heightened protection
under Rule 26(b)(3)(B), a party’s own mental impressions are nevertheless protected under Rule
26(b)(3), generally.
The importance of applying these protections to pro se litigants is magnified in the
context of AI—one of the most powerful knowledge tools ever to become available to the
masses. This is because pro se litigants are forced to act as both party and advocate,
simultaneously. See Gundlach & Smith, at 70 (quoting Boegh v. Harless, 2021 WL 1923365, at
*6 n.5 (W.D. Ky. May 13, 2021)). And for the first time in history, widespread access to
powerful technology may make that dual role surmountable. A reading of Rule 26(b)(3) that
conditions work product protection over AI materials on the involvement of counsel finds no
support in the rule’s text and would further disadvantage unrepresented litigants. Pro se litigants
are held to the same standard as represented litigants. See Requena v. Roberts, 893 F.3d 1195,
1205 (10th Cir. 2018). They should be afforded the same protections. See Nielsen v. Soc’y of
New York Hosp., 1988 WL 100197, at *2 (S.D.N.Y. Sep. 22, 1988) (saying, “[i]f plaintiff were
represented by counsel, his attorney’s notes in similar circumstances would not be subject to
production. A plaintiff appearing pro se is entitled to no less protection.”).
The Court is mindful of a recent decision that at first blush may appear contrary. See
United States v. Heppner, 2026 WL 436479 (S.D.N.Y. Feb. 17, 2026). In Heppner, the court
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observed that work product protections have historically been rooted in shielding the mental
impressions and legal theories of attorneys. Id. at *3. It concluded that a represented criminal
defendant who used an AI tool on his own initiative, without any direction or involvement from
their attorney, could not claim work product protection over the resulting materials. Id. at *3-4.
The Heppner decision is of course not binding on this Court, but even if it were, the case is
distinguishable for at least two reasons. First, Heppner was a criminal matter; this is a civil case
governed by the Federal Rules of Civil Procedure, and the text of Rule 26(b)(3) broadly protects
the work product of a party, not merely counsel. Second, in Heppner, there was a gap between
the party and the attorney because the defendant acted entirely apart from his lawyer. No such
gap exists in the pro se context. A pro se litigant is simultaneously the party and the advocate.
Here, like in Warner v. Gilbarco, Inc., 2026 WL 373043 (E.D. Mich. Feb. 10, 2026),
Plaintiff can assert work product protections in connection with his AI use. It is true that AI
systems like ChatGPT, Claude, Gemini, and others widely available to the public, collect user
data for training and other purposes. But in this Court’s estimation, that does not eliminate all
expectations of privacy or automatically waive protections.
Today, nearly all electronic interaction passes through third-party systems. Google, for
example, hosts millions of accounts, and by extension, has access to millions of messages,
emails, documents, videos, and more. Moreover, we now know that our phones, computers, in-
home smart devices, and other electronics, collect information about us to offer more bespoke
services. Does that mean that anyone with a Gmail account has forfeited all rights to
confidentiality and privacy? In United States v. Warshak, the Sixth Circuit held—albeit in the
context of a Fourth Amendment seizure analysis—that email subscribers have a reasonable
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expectation of privacy in the contents of emails stored with commercial internet service
providers. 631 F.3d 266, 268 (6th Cir. 2010). The court rejected the idea that intermediary access
alone extinguishes privacy expectations. Id. at 285-86. And though the Tenth Circuit did not
fully weigh in on this issue in United States v. Ackerman, 831 F.3d 1292, 1308 (10th Cir. 2016),
the Supreme Court has since held that the mere fact that information is held by a third-party
intermediary, does not automatically extinguish a reasonable expectation of privacy in that
information. Carpenter v. United States, 585 U.S. 296, 310-16 (2018).
The Fourth Amendment governs searches and seizures and offers a wholly different legal
framework from the work product doctrine, but the principle reflected in those cases is
informative: routing information through a third-party system does not forfeit all privacy.
Moreover, the case for privacy is arguably stronger in the context of modern AI use (as
contrasted with email use or cell site location). Unlike a general-purpose search engine, which
passively returns results, many modern AI platforms are specifically designed and trained to
engage. They invite candid and significant disclosure of information, including sensitive
information. They simulate empathy, foster trust, and interact in a way that feels genuine and
intimate.1 Research confirms that people share personal and sensitive information with AI
chatbots, often without appreciating what happens to that information once shared. See Jennifer
King et al., User Privacy and Large Language Models: An Analysis of Frontier Developers’
Privacy Policies, 8 P ROCEEDINGS OF THE AAAI/ACM C ONFERENCE ON AI, ETHICS , AND S OCIETY
1465 (2025) (noting that the conversational nature of AI chatbots encourages greater disclosure
1 The Court does not endorse these practices but simply notes them to describe the environment
in which AI users operate.
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of personal information than traditional search interfaces); see also Molly G. Smith, Thomas N.
Bradbury & Benjamin R. Karney, Can Generative AI Chatbots Emulate Human Connection? A
Relationship Science Perspective, 20 P ERSPECTIVES ON P SYCHOLOGICAL S CIENCE 1081 (2025).
Moreover, and in the context of a pro se litigant’s use of AI to assist with their litigation
preparation, the use of AI closely resembles the kind of confidential, strategy-laden iterative
work product that Rule 26(b)(3) was designed to protect. In other words, given how AI tools
function, it is entirely reasonable for a person to expect some privacy and confidentiality when
interacting with these tools, even though they understand a third party is behind the tool
collecting and storing their information.
In any event, work product protections are typically waived by disclosure to an
adversary, or in circumstances that substantially increase the likelihood that an adversary will
obtain the materials. United States v. Am. Tel. & Tel. Co., 642 F.2d 1285, 1297-1301 (D.C. Cir.
1980); see also Warner, 2026 WL 373043; In re Qwest Commc’ns Int’l Inc., 450 F.3d 1179,
1186 (10th Cir. 2006) (citing Foster v. Hill, 188 F.3d 1259, 1272 (10th Cir. 1999) for the
proposition that “the work-product doctrine is affected when a disclosure is to an adversary”). In
other words, even though AI use technically “discloses” information to a third party, it is highly
unlikely the information will fall into the hands of an adversary absent some legal process to
compel it. Thus, AI interactions do not automatically compromise work product protections. See
Warner, 2026 WL 373043, at *4 (finding that even if pro se plaintiff’s AI-generated information
is discoverable, it is subject to work product protection and the protections were not waived
because ChatGPT and other generative AI programs are tools, not persons, and the disclosure is
therefore not to an adversary or in a way likely to get in an adversary’s hands.)
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In sum, Rule 26(b)(3) applies and offers Plaintiff some level of work product protection
in connection with his use of AI. The question is, how far will that protection extend?
B. Scope of Rule 26(b)(3) Protections
Plaintiff seeks to shield from disclosure, not only the outputs from the AI system, but the
name of the AI tool he is using.
Some courts have applied the work product doctrine broadly to cover, for example,
processes not just outputs. See, e.g., Sporck v. Peil, 759 F.2d 312, 315 (3d Cir. 1985) (finding
that counsel’s selection process and grouping certain documents together out of the thousands
produced in litigation was work product entitled to protection under Rule 26(b)(3)). But the
Court does not need to delve into that issue here. Even if it is possible that in some contexts
disclosing an AI tool can reveal mental impressions or strategy, Plaintiff has not carried his
burden to demonstrate that here. See Martin v. Monfort, Inc., 150 F.R.D. 172, 172-73 (D. Colo.
1993) (describing the sequential step approach to resolving work product issues, and noting that
once the party seeking discovery establishes relevance, the burden shifts to the resisting party to
show the materials are protected work product); Pouncil v. Branch L. Firm, 277 F.R.D. 642, 653
(D. Kan. 2011) (noting that the proponent of a work product protection had the burden of
establishing that certain calendars, appointment books, and event logs contain information that
constitutes protected mental impressions). At best, Plaintiff states, in conclusory fashion and
without any legal or factual support, that “[t]he selection and use of specific litigation support
tools reveal a party’s mental impressions, case strategy, and legal resource allocation.” (Doc. No.
58 at 2; see also Doc. No. 58-1 (offering similar conclusory statements.).) But the Court cannot
discern from that, or any other information Plaintiff provides, how disclosing the name of an AI
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tool would reveal Plaintiff’s mental impressions or case strategy. Moreover, Defendant’s request
for the name of the tool is legitimate and reasonable. If Plaintiff already submitted Confidential
Information to some AI system—and it appears he has—Defendant is entitled to know which
system.
II. 	To what extent should a protective order restrict AI use?
The current Protective Order arguably covers the use of AI already,2 but the parties
appear to agree that a clarifying amendment is necessary.
Defendant asks the Court to add the following language to the Protective Order:
Restrictions on Use of AI to process Confidential or Highly Confidential
Information: Absent notice to and written permission from the producing
party, any person or entity authorized to have access to Confidential
Information under the terms of this Order:
a. shall not use or employ any application, service, or analytical software
that will transfer, transmit, send or allow access to Confidential
Information, in whole or in part – including metadata, unless such
application, service or analytical software:
i. does not further transfer the Confidential Information to another
provider, unless the receiving party has confirmed through due
diligence that the security and privacy controls of and contractual
obligations for such provider allow that party to comply with its
obligations under this Protective Order; and
ii. provides the receiving party the ability to remove or delete from
the system all Confidential information.
b. shall not permit any Confidential Information to be used to train any
artificial intelligence tool.
2 The current Protective Order broadly prohibits disclosure, not just to a person or entity, but
generally and in any fashion, except under specifically enumerated circumstances. (Doc. No. 30.)
Thus, “disclosure” in the form of transmission to an AI system with a provider that stores the
Confidential Information in their own databases, and/or for their own purposes, may violate the
current Protective Order.
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These restrictions apply to the use of advanced or generative AI tools from
OpenAI’s GPT or ChatGPT, Harvey.AI, Google’s Bard, Anthropic’s
Claude, and similar tools or applications.
(Doc. No. 52 at 2-3.) Plaintiff says Defendant’s proposed language is “overly broad,
technologically vague, and improperly attempt[s] to dictate the specific litigation strategies and
work-product tools utilized by a pro se litigant.” (Doc. No. 58 at 1-2.) Plaintiff also argues that
“Defendant’s language fails to account for the capabilities of professional-grade, closed-circuit
platforms that already ensure strict data isolation and prohibit machine learning training on user
data.” (Id.) Plaintiff proposes the following language instead:
Any party utilizing third-party software, cloud-based platforms, or
artificial intelligence tools for the storage, processing, review, or analysis
of Confidential Information must ensure that such tools operate within a
secure, closed-circuit environment. No Confidential Information may be
uploaded to any platform or service whose Terms of Service permit the
provider to utilize the uploaded data for the training of Large Language
Models (LLMs), machine learning algorithms, or for any internal human-
in-the-loop review.
(Doc. No. 58 at 5.) Defendant says Plaintiff’s proposed language does not offer sufficient
safeguards. (Doc. No. 60 at 3.) Defendant also advocates for its own proposal because it is
“narrowly-tailored.” (Id.)
Upon careful consideration of the issues and close review of the competing provisions,
the Court finds it appropriate to amend the Protective Order with a provision similar to
Defendant’s proposed provision, but tailored to the practical realities of this litigation and the
current dispute.
Defendant is correct that Plaintiff’s proposal does not offer sufficient guardrails. It allows
Confidential Information to be uploaded into an AI system so long as it operates in “a secure,
closed-circuit environment,” which seems to address cybersecurity concerns about unauthorized
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access rather than the distinct risks associated with today’s widely available AI platforms. (See
generally Doc. No. 58-1.) Moreover, to the extent Plaintiff’s proposal does address the unique
risks associated with AI, it does so in a very limited and vague way, prohibiting the uploading of
Confidential Information only when the provider’s terms of service “permit the provider to
utilize the uploaded data for the training of Large Language Models (LLMs), machine learning
algorithms, or for any internal human-in-the-loop review.” (Doc. No. 58 at 5.)
Defendant’s proposed language is better, but not without its shortcomings. It is, as
Defendant says, narrowly-tailored, but not in the way Defendant touts. Defendant’s proposed
language appears crafted to fit the precise bounds of Defendant’s contractual engagement with
AI providers, resulting in an over-engineered provision that feels vague to Plaintiff. (See Doc.
No. 58 at 1 (saying the provision is broad, vague, and an attempt to dictate his strategies and
tools).)3
Thus, instead of adopting the parties’ proposals, the Court will amend the Protective
Order to include the following AI-specific language:
No party or authorized recipient may input, upload, or submit
CONFIDENTIAL Information into any modern artificial intelligence
platform, including any generative, analytical, or large language model-
based tool (“AI”), unless the AI provider is contractually prohibited from:
(1) storing or using inputs to train or improve its model; and (2)
disclosing inputs to any third party except where such disclosure is
essential to facilitating delivery of the service. Where disclosure to a third
party is essential to service delivery, any such third party shall be bound
by obligations no less protective than those required by this Order. In
addition, the AI provider must contractually afford the party or authorized
recipient the ability to remove or delete all CONFIDENTIAL information
upon request. A party intending to use AI that it contends meets these
requirements must retain written documentation of these contractual
3 Defendant’s proposed provision also references “Google’s Bard,” which has since been
rebranded as Gemini.
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protections.
The Court recognizes that practically speaking, and in light of the current state of AI, this
provision will (at least for now) bar the parties from using most, if not all, mainstream low-to-no-
cost AI to process Confidential Information. This type of restriction disadvantages pro se
litigants.4 Enterprise-tier AI accounts that satisfy these requirements may be available only
through organizational procurement processes, or at costs that a pro se litigant is unlikely to
bear.5 But the Court cannot ignore the real risks associated with mainstream tools that
persistently collect and store data and could compromise confidentiality.
To be clear, the Court does not intend to leave pro se Plaintiff without the benefits of AI.
Modern AI tools may be used in many ways that do not involve uploading Confidential
Information, and nothing in this particular Order restricts those uses.6 What this Order requires is
that Confidential Information not be entrusted to platforms that lack the contractual safeguards
described above, regardless of the sophistication or apparent trustworthiness of the tool.
CONCLUSION
For these reasons, the Court GRANTS Defendant’s Motion in part, and DENIES it in
part as follows:
4 In light of this restriction, the parties are strongly cautioned against the over-designation of
Confidential Information.
5 This highlights a growing problem in the age of AI: as large firms pour thousands of dollars
into enterprise-grade AI and make their use of AI more secure, efficient, effective, and powerful,
how will a pro se litigant or a litigant who cannot afford big-ticket legal services and better AI
keep up?
6 Still, the parties must still comply with all applicable rules, litigation obligations, and the
presiding judge’s practice standards and orders when using AI.
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(1) The Court will enter an amended protective order reflecting the AI-specific
provision set forth in this Order; and
(2) Plaintiff is ORDERED to, within ten (10) days of this Order, disclose the name
of any AI platform he used to upload, submit, process, review, analyze, organize,
or store any information designated by Defendant as “CONFIDENTIAL” under
the Protective Order.
(3) Defendant is ORDERED to, within ten (10) days of Plaintiff’s disclosure, file a
Notice with this Court indicating whether it intends to seek relief from this Court
(and if so, what relief), or whether it has mitigated any potential harm or reached
agreement with Plaintiff, such that no relief will be necessary.
Dated this 30 th day of March, 2026.
BY THE COURT:
___________________________
Maritza Dominguez Braswell
United States Magistrate Judge
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