Reguli v. Woodruff et al

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
CONNIE REGULI, 	)
)
Plaintiff, 	)
)
v. 	) 	Case No.: 3:24-cv-00694
)
JOSEPH A. WOODRUFF, et al., 	) 	Judge Trauger
) 	Magistrate Judge Evans
Defendants. 	) 	JURY DEMAND
PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY MATERIAL
To facilitate document disclosure and production in the above-captioned action (the
“Litigation”) under the Local Rules of the Middle District of Tennessee and the Federal Rules of
Civil Procedure, and for good cause shown, this Protective Order shall apply to the Litigation and
remain in effect through the conclusion of the Litigation.
Documents 	and/or 	information 	containing 	confidential 	information 	(“Confidential
Information”) that bear significantly on the parties’ claims or defenses is likely to be disclosed or
produced during the course of discovery in the Litigation. The parties to the Litigation may assert
that public dissemination and disclosure of Confidential Information could severely injure or
damage the party disclosing or producing the Confidential Information or other third parties. To
protect the respective interests of the parties, and to facilitate the progress of disclosure and
discovery in this Litigation, the following Protective Order should issue:
IT IS THEREFORE ORDERED THAT:
1. 	Documents, including photographs, drawings, films, videotapes or other writings,
including lists or compilations thereof, answers to interrogatories, responses to other discovery
requests and deposition testimony or discovery by any party in this Litigation that qualify for
protection under Federal Rule of Civil Procedure 26(c) are referred to as “Confidential Material.”
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Except as otherwise indicated below, all documents, including photographs, drawings, films,
videotapes or other writings, including lists or compilations thereof, answers to interrogatories,
responses to other discovery requests and deposition testimony designated by the producing party
as “Confidential,” “Subject to Protective Order,” or any combination thereof, and which are
disclosed or produced to the parties or the attorneys for the parties to this Litigation are
Confidential Material and are entitled to Confidential treatment as described below.
2. 	Each party or non-party that designates information or items for protection under
this Order must take care to limit any such designation to specific material that qualifies under the
appropriate standards. If it comes to a designating party’s attention that information or items that
it designated for protection do not qualify for protection, that designating party must promptly
notify all other parties that it is withdrawing the mistaken designation.
3. 	A producing party may redact from any produced document the following
categories of personally identifying information of any person other than a party to this Litigation:
names; residential and email addresses; telephone numbers; employer identifications; financial-
account, routing, credit-card, and Social Security numbers; and dates of birth. A producing party
may also redact information identifying any child or family served by CASA. A producing party
shall apply such redactions in a manner that preserves the document's substantive content,
including all dates, transaction types, account categories, and amounts. Redaction pursuant to this
Paragraph does not constitute a withholding of responsive information and does not require a
privilege log. A party may challenge any redaction under Paragraph 5.
4. 	All documents marked Confidential and identified as exhibits to the deposition are
subject to this Order. All deposition testimony shall be treated as Confidential and subject to the
full protection of this Order for forty-five (45) days following the deposition. After such time,
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only those portions of any transcript designated as “Confidential” by a designating party shall be
deemed Confidential. To designate a portion of a transcript as “Confidential,” a party must provide
written notice to all parties and the stenographer identifying, by page and line number, the
Confidential testimony.
5. 	If at any time during the Litigation a party disputes the designation of discovery
material as Confidential, the objecting party will notify the designating party in writing of such
dispute, and request in writing a conference for the parties to confer in a good faith effort to resolve
the dispute. 	It shall be the responsibility of counsel for the objecting party to arrange for this
conference within fourteen (14) days of the request for a conference. The objecting party’s notice
will identify the material in dispute and explain the basis for the objection. 	If no response is
provided within fourteen (14) days of the objecting party’s request for a conference, then the
Confidential Material in dispute will no longer be subject to Confidential treatment as provided in
this Protective Order.
6. 	If the parties cannot resolve a challenge without court intervention, the designating
party shall file a Motion for Protective Order within fourteen (14) days of the parties agreeing that
the meet and confer process will not resolve their dispute. If the party or parties that designated
the material as confidential do not timely file a motion for protective order, then the designated
material in dispute shall no longer be subject to Confidential treatment as provided in this Order.
All material designated as Confidential are entitled to Confidential treatment pursuant to the terms
of this Order until and unless the parties formally agree in writing to the contrary, a party fails to
timely move for a protective order, or a contrary determination is made by the Court as to whether
all or a portion of the designated material is entitled to Confidential treatment.
7. 	The burden of persuasion in any such challenge proceeding shall be on the
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designating party. Frivolous challenges, and those made for an improper purpose (e.g., to harass
or impose unnecessary expenses and burdens on other parties) may expose the objecting party to
sanctions. 	Unless the designating party has waived the confidentiality designation by failing to
file a motion to retain confidentiality as described above, all parties shall continue to afford the
material in question the level of protection to which it is entitled under the designating party’s
designation until the Court rules on the challenge.
8. 	Confidential Material and any information contained therein shall not be used,
shown, disseminated, copied, or in any way communicated to anyone for any purpose whatsoever,
except as provided below. Confidential Material may be copied only by the parties or counsel for
the parties in the Litigation or by personnel or outside vendors assisting such counsel and only for
purposes permitted by this Protective Order, and control and distribution of Confidential Material
and copies thereof will be the responsibility of such party or counsel, who will maintain all written
assurances executed by such persons as provided in Paragraph 10.
9. 	Confidential Material and any information contained therein shall be disclosed only
to the following persons (“Qualified Persons”):
a. 	The named parties, including the officers, directors, and employees of the parties
to whom disclosure is reasonably necessary for the Litigation;
b. 	Counsel of record in the Litigation for the designating party or party receiving
Confidential Material or any information contained therein;
c. 	Employees of such counsel (excluding experts and investigators) assigned to and
necessary to assist such counsel in the preparation and trial of the Litigation;
d. 	An independent contractor or expert retained by counsel to provide assistance,
expert advice, technical consultation, language translation, or testimony in the
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Litigation and the employees of any such contractors, experts, consultants or similar
persons when working in connection with the Litigation under direct supervision
of said person;
e. 	Court reporters transcribing depositions in the Litigation;
f. 	Any witness at deposition (as contemplated by Paragraph 4), trial, or hearing in the
Litigation;
g. 	The Court (including the Court’s administrative and clerical staff).
Confidential Material shall not be disclosed to any other person or entity without the prior
written consent of the designating party or order of the Court. Any disclosure shall be only to the
extent reasonably necessary for the effective prosecution and defense of the claims in the
Litigation. 	Confidential Material and any information contained therein shall be used by the
receiving party or parties solely for the prosecution of the Litigation and shall not be used by the
receiving party or parties for any other purpose or in any other litigation.
10. 	Prior to the disclosure of any of the materials or information covered by this
Protective Order to persons identified in Paragraph 9 (d)–(f) of this Order, counsel disclosing the
materials or information shall present the person with a copy of this Order. 	After reading the
Order, such persons shall initial each page of a copy of the Order and shall sign the attached form
of “Acknowledgment of Protective Order” (the “Acknowledgement”). Copies of each such signed
Order and Acknowledgement shall be maintained by counsel disclosing the materials or
information. In the event that any of these individuals are identified or designated as witnesses or
as 	experts 	who 	may 	testify 	in 	the 	Litigation, 	a 	copy 	of 	each 	such 	signed 	Order 	and
Acknowledgement shall be provided to opposing counsel at the time of the designation.
11. 	The 	term 	“copy” 	as 	used 	herein 	means 	any 	photographic, 	mechanical 	or
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computerized copy or reproduction of any document or thing, or any verbatim transcript, in whole
or in part, of such document or thing.
12. To the extent that Confidential Material or information contained therein is used in
depositions, such documents or information shall remain subject to the provisions of this Protective
Order.
13. Any court reporter or transcriber who reports or transcribes testimony in the
Litigation shall agree that all Confidential Material designated under this Order shall remain as
such and shall not be disclosed by them, except pursuant to the terms of this Protective Order, and
that any notes or transcriptions of such testimony (and any accompanying exhibits) will be retained
by the reporter or delivered to counsel or the parties.
14. Without written permission from the designating party or a Court order secured
after appropriate notice to all interested persons, a party may not file in the public record in this
action any Confidential Material. A party that seeks to file under seal any Confidential Material
must comply with Local Rule 5.03. If a party’s request to file Confidential Material under seal
pursuant to Local Rule 5.03 is denied by the Court, then the party may file the information in the
public record, unless otherwise instructed by the Court.
15. Documents unintentionally produced without designation as “Confidential” at any
time during the Litigation may be retroactively designated by notice in writing of the designated
classification applicable to each document by Bates number, and by providing replacement copies
of such documents with the appropriate designation. Upon receipt of the replacement documents,
the receiving party shall thereafter return the documents being replaced to the producing party.
Such documents shall be treated as “Confidential” from the date written notice of the designation
is provided to the receiving party. A person disclosing any materials that are subsequently
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designated as “Confidential” shall assist, in good faith, the party making the supplemental
designation in retrieving such materials from all recipients not entitled to such materials under the
terms of this Protective Order and to prevent further disclosures except as authorized under the
terms of this Protective Order. Documents to be inspected shall be treated as “Confidential” during
inspection. At the time of copying for the receiving parties, such inspected documents shall be
stamped prominently “Confidential” by the producing party.
16. Pursuant to Federal Rule of Evidence 502(d) the production of a privileged or work-
product-protected document, whether inadvertent or otherwise, is not a waiver of privilege or
protection from discovery in this case or in any other federal or state proceeding. Said protection
exists with respect to such document or other documents or communications, written or oral,
including, without limitation, other communications referred to in the documents produced. Upon
request, such inadvertently produced documents, and all copies thereof, shall be sent to the
producing party, sequestered or destroyed within five (5) days of the date of the request, unless
such documents have already been filed with the Court. Furthermore, a party’s production shall
not be deemed a waiver of any party’s right to object for any reason to the admission of any
document or thing into evidence, nor shall the production be deemed an admission of its
admissibility or relevance. Nothing in this Paragraph shall prejudice the right of any party to seek
discovery or communications, documents and things as to which a claim of attorney-client
privilege or attorney work-product has been made.
17. The party or parties receiving Confidential Material shall not under any
circumstances sell, offer for sale, advertise, publicize, post, or disseminate on any website, social-
media platform, blog, podcast, or to any member of the media, use in any other judicial,
administrative, legislative, disciplinary, or licensing proceeding, or use in any public
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communication, whether or not for compensation, Confidential Material or any information
contained therein.
18. 	No Party or Qualified Person shall input, upload, or otherwise submit any
Confidential Material other than its own, whether designated as Confidential Material or not, into
any public or “open” generative artificial intelligence tool, large language model, or similar
platform (e.g., the non-enterprise versions of ChatGPT, Claude, or Gemini). Submission of such
Confidential Material to such tools is deemed a disclosure to a non-authorized third party and a
violation of this Order, as open artificial intelligence tools may retain and use inputs to train or
fine-tune their models, making it practically impossible for a person that uploads Confidential
Material to such a tool to ensure its destruction. A Party or Qualified Person may only use the
following “closed” tools:
a. 	Established legal research services (e.g., Westlaw, Lexis) with generative artificial
intelligence features and that provide contractual guarantees that user inputs are (i)
not used to train the underlying model and (ii) are not accessible to third parties;
b. 	Secure case management or discovery platforms (e.g., Relativity, Everlaw)
including generative artificial intelligence features that maintain appropriate
security certifications and provide a “zero-retention” or “no-training” policy for
user data; and
c. 	Artificial intelligence tools provided through a secure enterprise agreement that
explicitly (i) prohibits the tool developer from accessing or using the data for any
purpose other than providing the service to the Party or Authorized Recipient; (ii)
ensures the data is isolated from other uses; and (iii) provides for the permanent
deletion of data upon request.
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19. 	If any party receives a subpoena from any non-party to this Protective Order
seeking production or disclosure of Confidential Material, the subpoenaed party shall give notice,
as soon as practicable and in no event more than three (3) business days after receiving the
subpoena and at least seven (7) business days before providing materials responsive to the
subpoena, to counsel for the designating party or the designating party, which notice will enclose
a copy of the subpoena, such that the designating party may assert its rights, if any, to non-
disclosure.
20. 	Any documents produced by a non-party witness in discovery in the Litigation
pursuant to subpoena or otherwise may be designated by such non-party as “Confidential” under
the terms of this Order, and such designation shall have the same force and effect, and create the
same duties, obligations, and remedies as if made by one of the parties hereto.
21. 	After termination of the Litigation, the provisions of this Protective Order shall
continue to be binding, except with respect to those documents and information that become a
matter of public record. This Court retains and shall have continuing jurisdiction over the parties
and recipients of the Confidential Material for enforcement of the provisions of this Protective
Order following termination of the Litigation.
22. 	Within thirty (30) days of termination of the Litigation by dismissal, judgment, or
settlement, including any appeals, the party or parties receiving Confidential Material shall return
the Confidential Material, including all copies to the party or parties disclosing or producing the
Confidential Material or alternatively, the parties shall provide certification under oath under
penalty of perjury under the laws of the United States of America confirming that the receiving
party has destroyed all documents within their possession, custody or control. The party or parties
receiving Confidential Material shall undertake reasonable and good faith efforts to ensure that
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any person to whom they provide copies of any Confidential Information complies with this
obligation. 	This provision will not apply to court filings or file copies of pleadings, briefs or
correspondence or other work product maintained by the parties’ respective counsel in the ordinary
course of business.
23. 	This Protective Order shall be binding on any party to this Protective Order or any
person having executed the attached Exhibit A. This Protective Order also shall be binding upon
the parties and their attorneys, successors, executors, personal representatives, administrators,
heirs, legal representatives, assigns, subsidiaries, divisions, employees, agents, independent
contractors, or other persons or organizations over which they have control.
24. 	This Protective Order is without prejudice to the right of any party to move the
Court for an order for good cause shown for protection of Confidential Material sought by or
produced through discovery, which protection is different from or in addition to that provided for
in this Protective Order, and such right is expressly reserved.
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DATED: ____________________, 2026.
___________________________________
Magistrate Judge Luke Evans
September 15
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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
CONNIE REGULI, 	)
)
Plaintiff, 	)
)
v. 	) 	Case No.: 3:24-cv-00694
)
JOSEPH A. WOODRUFF, et al., 	) 	Judge Trauger
) 	Magistrate Judge Evans
Defendants. 	) 	JURY DEMAND
ACKNOWLEDGMENT OF PROTECTIVE ORDER
I hereby acknowledge that I have read the Protective Order Regarding Confidential
Discovery Material (“Protective Order”) entered in Reguli v. Joseph A. Woodruff, et al., Case No.
3:24-cv-00694, understand its terms, agree to be bound by each of those terms, and agree to submit
myself to the jurisdiction of the United States District Court for the Middle District of Tennessee,
Nashville Division, for the purposes of enforcing the terms of the Protective Order.
Specifically and without limitation upon such terms, I further agree that I will not
disseminate, use or disclose any Confidential Material protected by the Protective Order that I have
received and/or reviewed in this case to anyone other than the Qualified Persons defined in
Paragraph 9 of the Protective Order.
Dated: ___ day of ________________, 2026.
Signature
Printed Name:
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