BRIONES v. TAURUS INTERNATIONAL MANUFACTURING INC et al

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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
ALBANY DIVISION
JOSE RAUL BRIONES, JR.,
Plaintiff,
)
)
)
)
v. 	) 	Case No. 1:24-CV-00082 (LAG)
TAURUS INTERNATIONAL
MANUFACTURING, INC.,
TAURUS HOLDINGS, INC.;
Defendants.
)
)
)
)
)
)
)
STIPULATED PROTECTIVE ORDER
Disclosure and discovery activity in this lawsuit are likely to involve production of
confidential, proprietary, or private information for which special protection from public
disclosure and from use for any purpose other than prosecuting this lawsuit may be warranted.
Accordingly, the parties in this case (each a “Party”) hereby agree and stipulate to the following
Protective Order.
The purpose of this Protective Order is to protect discovery material that is confidential or
privileged and facilitate the prompt resolution of disputes over confidentiality and privilege,
pursuant to the Court’s inherent authority, its authority under Federal Rule of Civil Procedure 26(c)
and Federal Rule of Evidence 502(d), and the judicial opinions interpreting such Rules. 	The
protections conferred by this Protective Order cover not only Confidential Information (as defined
herein), but also (1) any information copied or extracted from Confidential Information; (2) all
copies, excerpts, summaries, or compilations of Confidential Information; and (3) any testimony,
conversations, or presentations by Parties or their Counsel that might reveal Confidential
Information.
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1. “Information” and “Confidential Information.”
1.1 Information. “Information” includes the contents of documents and other data, any
data and information derived from or associated with documents (whether physical or in electronic
format), oral and written testimony, answers to interrogatories, admissions, and data and
information derived from objects other than documents, produced or disclosed in these
proceedings by any Party named in the lawsuit or by any third-party (the “Producing Party”) to
any other Party or Parties (the “Receiving Party”).
1.2 Determination of Information as “Confidential Information.” Any Producing
Party may designate Information as “Confidential Information” (also called Information
designated as “CONFIDENTIAL”) when that Producing Party reasonably believes that the
Information constitutes, reflects, discloses, or contains any of the following: (a) any Information
subject to protection under Federal Rule of Civil Procedure 26(c) or confidential technical,
proprietary, commercial, personal or financial information, including but not limited to
information containing competitively sensitive information regarding trade secrets, product
designs or strategies, testing, research-and-development information, technical, marketing,
business plans, sales and cost information, pricing information, production schedules, contracts,
commercial or financial information, or other sensitive information, the disclosure of which to
third-party competitors may result in commercial harm; (b) any Information protected by federal,
state, or foreign data protection laws or other privacy obligations; or (c) any Information controlled
or governed by U.S. federal firearms regulations, such as: (i) the International Traffic in Arms
Regulation; (ii) the Arms Export Control Act; (iii) the Export Administration Regulations; and (iv)
any similar regulations restricting or otherwise governing the import or export of information or
data related to firearms and associated technology.
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2. Procedure for Confidentiality Designations.
2.1. Information that meets any of the above qualifications may be designated by a Party
or Non-Party as “Confidential Information” or “CONFIDENTIAL” according to the following
provisions. A Producing Party (i.e., a Party or Non-Party) or a Party that designates Information
as “Confidential Information” according to this Protective Order is referred to herein as the
“Designating Party.”
2.2. A Producing Party may designate a document as Confidential Information for
protection under this Protective Order by placing or affixing the word “CONFIDENTIAL” to each
page, an entire document, or family of documents that contains Confidential Information and on
all copies in a manner that will not interfere with the legibility of the document. For documents
produced in native format, the Producing Party must identify in written correspondence the
electronically stored information designated as CONFIDENTIAL; to the extent technologically
feasible, the Producing Party must include the word “CONFIDENTIAL” in the native file name,
on the media containing the Confidential Information (e.g., CD-ROM), and on a Bates-numbered
slip sheet produced with the native file. For information produced in some form other than
documentary and for any other tangible items, the Producing Party may designate the item as
containing Confidential Information by affixing the legend “CONFIDENTIAL” in a prominent
place on the exterior of the container or containers in which the information is stored.
As used in this Protective Order, “copies” includes electronic images, duplicates,
compilations, extracts, summaries, or descriptions that contain or capture the Confidential
Information. The marking “CONFIDENTIAL” shall be applied by a Producing Party prior to or
at the time the documents are produced or disclosed. Any copies that are made of any documents
marked “CONFIDENTIAL” shall also be so marked, except that indices, electronic databases, or
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lists of documents that do not contain substantial portions or images of the text of marked
documents and do not otherwise disclose the substance of the Confidential Information are not
required to be marked.
2.3. Deposition or other testimony may be designated as Confidential Information by
any one or more of the following means: (i) by stating orally on the record that the information is
Confidential Information under the Protective Order; (ii) by sending written notice to all Parties of
the specific page and line designations over which the “CONFIDENTIAL” designation is claimed,
within 30 days after receipt of a copy of the transcript from the court reporter; or (iii) by stamping
or writing the legend CONFIDENTIAL on the relevant pages or portions of the transcript at or
before the signing of the deposition transcript by the witness. All information disclosed during a
deposition shall be deemed to have been designated as Confidential Information until the
expiration of the later of the time within which the witness may sign the transcript, whether or not
any portion of the transcript has been designated previously, or ten days after receipt of a copy of
the deposition transcript from the court reporter. When notified to do so, persons attending
depositions, other than the witness and the witness’s counsel (provided that the witness and his/her
counsel have signed the agreement attached as Exhibit A), must leave the room before any
discussion of any Confidential Information, or any excerpts, summaries, or information derived
therefrom, that the person attending the deposition is not entitled to review or receive under this
Protective Order.
2.4. A Producing Party that makes original documents or materials available for
inspection may designate them as Confidential Information prior to the inspection. Alternatively,
the Producing Party making such materials available may designate the materials after the
inspecting Party has indicated which material it would like copied and produced. In that event,
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during the inspection and before the designation, all of the material made available for inspection
shall be deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents that
it wants copied and produced, the Producing Party must determine which documents qualify for
protection under this Protective Order. Then, before producing the specified documents, the
Producing Party must affix the “CONFIDENTIAL” legend to each page or item that contains
Confidential Information, or must send written notice to all Parties of the specific materials and
documents over which the “CONFIDENTIAL” designation is claimed.
2.5. A Party may redact from the documents and things it produces information that the
Party claims is subject to attorney-client privilege, work-product protection, a legal prohibition
against disclosure, or any other privilege or immunity. Any Party may also redact from the
documents and things it produces irrelevant and nonresponsive information that is competitively
sensitive (including but not limited to proprietary financial information, marketing/business plans,
and research-and-development information about products or components unrelated to this case).
The Party shall mark each document or thing where matter has been redacted with a legend
providing notice of the basis for redaction. Where a document consists of more than one page,
each page on which Information has been redacted shall be so marked. The Party shall preserve an
unredacted version of each such document. The process for challenging the designation of
redactions shall be the same as the process for challenging the designation of Confidential
Information set forth below. If counsel for the Party redacting commercially sensitive and
irrelevant Information agrees that Information initially redacted should not be subject to redaction,
or if the Court orders that those materials shall not be subject to redaction or shall receive
alternative treatment, and the redacted Information is subsequently produced in unredacted form,
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then that unredacted Information may bear the legend “CONFIDENTIAL” and receive the
protection afforded to documents bearing that designation, unless otherwise ordered by the Court.
2.6. Failure by a Party to designate qualified Confidential Information or items as such
does not, standing alone, waive that Party’s right to secure protection under this Protective Order
for such Information. In the event that Confidential Information is inadvertently disclosed without
a marking or designation of it as such, the Producing Party may thereafter assert a claim or
designation of confidentiality by identifying the Information that was not correctly designated,
such as providing the Bates numbers of such Information or the portions of testimony. For
document productions, the Producing Party shall promptly provide replacement media bearing the
required designations. Upon receipt of the replacement media, the Receiving Party shall make no
use of the copies of the Confidential Information originally produced without the required
designations.
2.7. Designation of Information Produced by a Third-Party. Prior to or at the time
of disclosure, a third-party may designate Information as Confidential Information according to
the procedures above. With respect to any Information (including documents, testimony, or other
material) that is produced or disclosed by any third-party without a designation of
“CONFIDENTIAL,” any Party may designate any undesignated Information disclosed by a third-
party by written notice to all Parties within twenty-one days of the Party’s receipt of the third-
party’s disclosure, or such other time as may be agreed upon by the Parties. In such written notice,
the Designating Party shall either provide the Bates number(s) or other unique identifiers of the
material in the written notice or provide a copy of the designated material bearing the appropriate
legend. For deposition testimony, such written notice shall comply with the provisions in Section
2.3 above. Upon notice of designation pursuant to this Paragraph, the Parties shall: (i) make no
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further disclosure of such designated material or information contained therein, except as allowed
under this Protective Order; (ii) take reasonable steps to notify any persons who were provided
copies of such designated material of the terms of this Protective Order; and (iii) take reasonable
steps to reclaim any such designated material in the possession of any person not permitted access
to such Information under the terms of this Protective Order. No Party shall be deemed to have
violated this Protective Order for the sole reason that such material has been disclosed or used in
a manner inconsistent with the subsequent designation, prior to notification of the subsequent
designation.
2.8. Any Party may object to the propriety of the designation of specific material as
Confidential Information (the “Challenging Party”) by serving a written objection upon the
Designating Party’s counsel specifying the documents or things that it challenges, by Bates
Number, and separately explaining the basis for the specific challenge for each document or thing
designated. To avoid ambiguity as to whether a challenge has been made, the written notice must
recite that the challenge to confidentiality is being made in accordance with this Protective Order.
The Designating Party or its counsel shall thereafter, within fifteen days, respond to such objection
in writing by either of the following: (i) agreeing to remove the designation; or (ii) stating the
reasons for such designation. Counsel may agree to a reasonable extension of the fifteen-day
period, if necessary. If the Challenging Party and the Designating Party are subsequently unable
to agree upon the terms and conditions of disclosure for the material(s) in issue, the Challenging
Party may move the Court for an order withdrawing the designation as to the specific Information
on which the Parties could not agree. On such a motion, the Designating Party shall have the
burden of proving that “good cause” exists for the designation at issue and that the material is
entitled to protection under this Protective Order. All Information designated as Confidential
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Information shall be deemed to be subject to this Protective Order and continue to be treated in the
manner as designated by the Designating Party unless and until the Court has ruled to the contrary.
Each Party and third-party shall bear its own fees and costs related to any challenges of
confidentiality designations under this Protective Order.
2.9. To expedite production of potentially voluminous materials, a Producing Party
may, but is not required to, produce materials without a detailed confidentiality review. In so doing,
the Producing Party may designate those collections of documents that by their nature would
ordinarily contain Confidential Information with the appropriate designation notwithstanding that
some of the documents within the collection may not qualify for such designation. The materials
that may be so designated shall be limited to the types or categories of documents that the
Producing Party reasonably believes may contain Confidential Information.
3. Restrictions on Use of and Access to Confidential Information.
3.1 Restriction on Use of Confidential Information. Confidential Information cannot
be used or shown, disseminated, copied, or in any way communicated to any person for any
purpose whatsoever other than for prosecuting, defending, or attempting to settle this lawsuit,
Michael T. Shelton v. Taurus International Manufacturing, Inc., Civil Action No. 1:23-cv-00214-
LAG (M.D. Ga.), and only in compliance with this Protective Order. Use of Confidential
Information in any other litigation or for any other purpose is expressly prohibited. Counsel for
the Parties to whom Confidential Information has been furnished shall be responsible for
restricting disclosure in accordance with the provisions of this Protective Order. Confidential
Information must be stored and maintained in a secure manner in order to limit access to the
persons authorized under this Protective Order. Receiving Parties will develop, implement,
maintain, and use appropriate administrative, technical, and physical safeguards to preserve the
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a) 	The Court and its staff;
b) 	The counsel charged with the responsibility for, or actively engaged in,
preparation for trial or the trial of this lawsuit, or an appellate proceeding or
settlement arising from this case, and the direct staff of those lawyers,
provided that these individuals first sign the agreement that is attached as
Exhibit A;
c) 	The Parties named in this lawsuit, and the Parties’ officers, directors,
employees, former employees, and in-house lawyers engaged in assisting
the Parties’ counsel in the conduct of this case, to the extent deemed
reasonably necessary by counsel of record;
privacy, integrity, and confidentiality of any Confidential Information, and to prevent unpermitted
use or disclosure of any Confidential Information they may receive from any person in connection
with this case. Receiving Parties shall not under any circumstance sell, offer for sale, advertise, or
publicize the Confidential Information or the fact that such persons have obtained a Producing
Party’s or Designating Party’s Confidential Information.
3.2. Access to Confidential Information. Counsel for the Parties to whom
Confidential Information has been furnished will be responsible for restricting disclosure in
accordance with the provisions of this Protective Order. Confidential Information may not be
disclosed to absent members of a putative or certified class who have not intervened or otherwise
appeared in this lawsuit. Unless otherwise ordered by the Court or permitted in writing by the
Designating Party, a Receiving Party may disclose information designated as CONFIDENTIAL
only to the following persons:
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d) 	Defendants’ insurers and its insurers’ employees who have signed the
agreement attached as Exhibit A;
e) 	Court reporters (including audio and video), interpreters, translators, copy
services, graphic support services, document imaging services, and e-
discovery, database or coding services retained by counsel for purposes of
this case, provided that these individuals or an appropriate company official
with authority to do so on behalf of the company executes the agreement
that is attached as Exhibit A;
f) 	Individual experts and/or individual consultants retained or employed to
advise or assist counsel for the Receiving Party in prosecuting or defending
claims in this case, to whom disclosure is reasonably necessary for this
lawsuit and provided that these individuals first sign the agreement attached
as Exhibit A;
g) 	Mediators and their employees who are actively engaged in assisting the
mediators in connection with this case and who have signed the agreement
attached as Exhibit A;
h) 	Any witness during their deposition or testimony at trial or any hearing,
provided that counsel for the Party intending to disclose the Confidential
Information has a good-faith basis for believing that it is relevant to events,
transactions, discussions, communications or data about which the witness
is expected to testify or about which the witness may have knowledge.
Witnesses shall not retain a copy of documents containing Confidential
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Information, except witnesses may receive a copy of all exhibits marked at
their depositions in connection with review of the transcripts; and
i) 	The 	author 	or 	recipient 	of 	a 	document 	containing 	the 	Confidential
Information or a custodian who otherwise possessed the Confidential
Information.
3.3. Restrictions on a Receiving Party’s Use of Artificial Intelligence. To ensure the
protection of confidentiality, privacy, and the integrity of all Confidential Information produced
in this lawsuit, the Receiving Party shall not input, upload, transcribe, or otherwise use any
Confidential Information produced in this matter in any Artificial Intelligence/AI or “GenAI”
platforms, applications, or services. This includes the prohibition to input, upload, transcribe, or
otherwise use any publicly accessible generative language models, or software platforms that
incorporate generative language models.
3.4. 	Filings. A Receiving Party may not file in the public record any Confidential
Information without written permission from the Designating Party or a Court order secured after
appropriate notice to all interested persons. Unless otherwise agreed to by the Designating Party
or ordered by the Court, all pleadings, motions, memoranda, briefs, deposition transcripts,
discovery requests and responses, exhibits, and other documents that produce, quote, paraphrase,
summarize, or otherwise contain information from Confidential Information, if filed with the
Court, shall either be redacted from the Court filing or filed under seal pursuant to the agreements
in this Protective Order and the rules governing sealed documents, as set forth in the applicable
Local Rules.
3.5. 	Hearings. In the event that a Receiving Party intends to utilize Confidential
Information during a pre-trial hearing, such Receiving Party shall provide written notice no less
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than five days prior to the hearing, to the Producing Party and to the Court, except that shorter
notice may be provided if the Receiving Party could not reasonably anticipate the need to use the
document at the hearing five days in advance, in which event notice shall be given immediately
upon identification of that need. The use of such Confidential Information during the pre-trial
hearing shall be determined by agreement of the Parties or by order of the Court. Confidential
Information will retain its confidential status even if used at hearings.
3.6. Material Subpoenaed or Ordered Produced in Other Litigation. If a Party
receives a discovery request, subpoena, or order issued in other litigation that seeks or otherwise
orders production of Confidential Information that has been designated under the terms of this
Protective Order, the Party or other person to whom the request, subpoena, or order or other
process is directed must:
(a) notify all counsel of record for the Designating Party in writing by email and overnight
delivery within five days of receipt of the discovery request, subpoena, or order. Such notification
shall include a copy of the discovery request, subpoena, or order. Such notification shall also
include: (i) the discovery materials that are requested for production; (ii) the date by which
compliance is requested; (iii) the location at which compliance is requested; (iv) the identity of the
party serving the subpoena or request; and (v) the case name, jurisdiction and index, docket,
complaint, charge, civil action or other identification number or other designation identifying the
relevant action, administrative proceeding, or other proceeding in which the discovery request,
subpoena, or other process has been issued.
(b) promptly notify in writing the party who caused the subpoena or order to issue in the
other litigation that some or all of the material covered by the subpoena or order is subject to this
Protective Order. Such notification shall include a copy of this Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Confidential Information may be affected.
The Party or person subject to such discovery request or subpoena shall not produce or
disclose the Confidential Information unless the Designating Party consents in writing or a court
of competent jurisdiction orders the production.
3.7. Unauthorized Disclosure. If a Receiving Party learns that, by inadvertence or
otherwise, it has disclosed Confidential Information to any person or in any circumstance not
authorized under this Protective Order, the Receiving Party must immediately (a) notify in writing
the Producing Party (and if a different entity, the Designating Party) of the unauthorized
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Confidential
Information, (c) inform the person or persons to whom unauthorized disclosures were made of all
the terms of this Protective Order, and (d) request such person or persons to execute the agreement
attached as Exhibit A.
4. Miscellaneous.
4.1. Nothing in this Protective Order prevents a Party or third-party from disclosing its
own documents and information as it sees fit. Any use or discussion of Confidential Information
shall not be deemed to be a waiver of any designation under this Protective Order or the terms of
this Protective Order.
4.2. The use of Confidential Information during the trial shall be determined by order
of the Court. Confidential Information will retain its confidential status even if used at trial.
4.3. No provision in this Protective Order shall be construed as requiring the production
or disclosure of any documents or information. By stipulating to the entry of this Protective Order,
no Party waives any right it otherwise would have to object to disclosing or producing any
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4.4. 	This Protective Order may be modified or amended either by written agreement of
the Parties submitted to the Court for approval or by Order of the Court upon good cause shown.
5. Federal Rule of Evidence 502(d) and Clawback Agreement.
5.1 	Pursuant to Federal Rules of Evidence 502(d) and (e), the Parties agree to and the
Court orders protection of privileged and otherwise protected Information against claims of waiver
(including as against third-parties and in other federal and state proceedings) as follows:
5.1 	No Waiver by Disclosure.
(a) 	If a Party discloses Information in connection with this lawsuit that the Party
thereafter claims to be privileged or protected by the attorney-client privilege and/or work-product
doctrine 	(“Disclosed 	Protected 	Information”), 	the 	disclosure 	of 	the 	Disclosed 	Protected
Information shall not constitute or be deemed a waiver or forfeiture of any claim of privilege or
work-product protection that the Producing Party would otherwise be entitled to assert with respect
to the Disclosed Protected Information and its subject matter in this lawsuit or in any other federal
or state proceeding.
(b) 	This Protective Order shall be interpreted to provide the maximum protection
allowed by Federal Rule of Evidence 502(d). The Parties intend that this Protective Order shall
displace the provisions of Federal Rules of Evidence 502(b)(l) and (2). That is, all disclosures
information on any ground not addressed in this Protective Order. Nothing in this Protective Order
or done by a Party pursuant to this Protective Order shall preclude the Parties from raising any
available objection or seeking any available protection with respect to any Information, including
but not limited to the grounds of admissibility of evidence, materiality, trial preparation materials,
and privilege.
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during discovery in this case shall be regarded as “inadvertent,” and the Parties are hereby deemed
to have taken “reasonable steps to prevent disclosure.”
(c) 	A Party may assert in writing attorney-client privilege or work-product protection
with respect to Disclosed Protected Information. The Receiving Party must – unless it contests the
claim of attorney-client privilege or work product protection in accordance with sub-paragraph (c)
below – within five business days of receipt of that writing, (i) return or destroy all copies of the
Disclosed Protected Information (including destroying all notes, abstracts or compilations of the
content thereof), and (ii) provide a certification of counsel that all of the Disclosed Protected
Information has been returned or destroyed.
(d) 	If the Receiving Party contests the claim of attorney-client privilege or work-
product protection, the Receiving Party must—within fifteen days of receipt of the claim of
privilege or protection—move the Court for an order compelling disclosure of the Disclosed
Protected Information (a “Disclosure Motion”). The Receiving Party must seek to file the
Disclosure Motion under seal and must not assert as a ground for compelling disclosure the fact
or circumstances of the disclosure, and may not disclose, rely on or refer to any of the Disclosed
Protected Information. Pending resolution of the Disclosure Motion, the Receiving Party must
sequester the Disclosed Protected Information and not use the Disclosed Protected Information or
disclose it to any person other than as required by law.
(e) The Parties may stipulate to extend the time periods set forth in sub-paragraphs (c) and
(d).
(f) Disclosed Protected Information that is sought to be reclaimed by the Parties to this
lawsuit pursuant to this Protective Order shall not be used as grounds by any Party or third-party
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to argue that any waiver of privilege or protection has occurred by virtue of any production in this
lawsuit.
(g) The Producing Party that produced the Disclosed Protected Information retains the
burden of establishing the privileged or protected nature of the Disclosed Protected Information.
(h) If the Court sustains the claim that the material disclosed, exchanged, produced, or
discussed is Privileged Material, the Receiving Party must, within ten days of the Court’s order,
promptly return and/or destroy the material (including destroying all notes, abstracts or
compilations of the content thereof) and all the privileged or work-product material. The Receiving
Party shall advise the Producing Party in writing of the return and/or destruction.
Nothing contained herein is intended to limit a Party’s right to conduct a review of
documents, data (including electronically stored information), and other information, including
without limitation, metadata, for relevance, responsiveness and/or the segregation of privileged
and/or protected information before such information is produced to another Party. The Parties
expressly acknowledge that each Producing Party shall have the right, at its sole discretion, to
review documents for responsiveness and privilege, prior to production.
5.2. 	If a Receiving Party becomes aware of any Disclosed Protected Information from
another Producing Party is or may be reasonably subject to the attorney-client privilege or work-
product doctrine, then counsel for the Receiving Party shall immediately (i) cease any further
review or use of that document or material, and (ii) notify the Producing Party of the apparent
production of Disclosed Protected Information, requesting whether the documents or materials are
Disclosed Protected Information. If the Producing Party intends to assert a claim of privilege or
other protection over Information identified by the Receiving Party as Disclosed Protected
Information, the Producing Party will, within ten days of receiving the Receiving Party’s written
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notification described above, inform the Receiving Party of such intention in writing and within a
reasonable time thereafter provide the Receiving Party with information for such Disclosed
Protected Information that is consistent with the requirements of the Federal Rules of Civil
Procedure or any applicable order of the Court governing privilege logs in this matter, setting forth
the basis for the claim of privilege or other protection.
In the event the Producing Party confirms the documents or material are Disclosed
Protected Information, the Receiving Party shall (i) promptly return or destroy all copies of the
Disclosed Protected Information in its possession, and (ii) take reasonable steps to retrieve all
copies of the Disclosed Protected Information distributed to others. If a Receiving Party learns
that, by inadvertence or otherwise, it has disclosed privileged information to any person or in any
circumstance not authorized under this Protective Order, the Receiving Party must immediately
(1) notify in writing the Designating Party of the unauthorized disclosures, (2) use its best efforts
to retrieve all unauthorized copies of the privileged information, (3) inform the person or persons
to whom unauthorized disclosures were made of all the terms of this Protective Order, and (4)
request such person or persons to execute an agreement in the form attached hereto as Exhibit A.
6. Privilege Log Production.
6.1 Unless otherwise provided in this Protective Order, any document falling within
the scope of any request for production or subpoena that is withheld on the basis of a claim of
attorney-client privilege, work product, or any other claim of privilege or immunity from discovery
is to be identified by the Producing Party on a privilege log, which the Producing Party shall
produce within sixty days of the production of underlying documents. For administrative purposes,
an e-mail thread contained within a single document need only be recorded once on the Producing
Party’s privilege log, even if a privilege is asserted over multiple portions of the thread. Redacted
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documents need not be logged, provided that: (a) for emails, the bibliographic information (i.e. to,
from, cc, bcc, recipients, date and time) is not redacted, and the reason for the redaction is noted
on the face of the document; and (b) for non- email documents, the reason for the redaction is
noted on the face of the document. Documents that are redacted shall be identified as such in the
accompanying data load file, such as in a “redaction” field.
6.2. Privilege log identification is not required for work product created by counsel, or
by an agent of counsel other than a Party, after December 8, 2023, or for post-December 8, 2023,
communications exchanged between or among the Producing Party and its counsel. Privilege log
identification is also not required for (i) communications between a Producing Party and its
counsel of record in proceedings other than those communications related to the above-captioned
lawsuit; (ii) work product created by a Producing Party’s counsel, or by an agent or contractor of
counsel other than the Producing Party, in proceedings other than the above-captioned lawsuit;
(iii) internal communications within a law firm representing a Producing Party or a legal
department of a Producing Party that is a corporation or other legal organization.
6.3. To avoid unnecessary cost, the Parties are encouraged to identify categories of
privileged Information that may be logged categorically rather than document-by-document. See
Advisory Committee Note to Fed. R. Civ. P. 26(b)(5) (1993). The Parties shall meet and confer on
this issue. The Parties will keep in mind the need to minimize the cost and resources devoted to
privilege logging, while enabling the Court and Receiving Party to assess the assertions of
privilege made by the Producing Party. The Parties may agree on documents that the Parties may
log by category, and/or the Parties may raise with the Court proposals for categorical privilege
logging.
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_________________________
Hon. Leslie A. Gardner, Chief Judge
United States District Court
7. Final Disposition.
Unless otherwise agreed to in writing by the Producing Party and Designating Party, within
sixty days after the final termination of this case (including any appeals), each Receiving Party
and its employees, attorneys, consultants, and experts must (at the Receiving Party’s election)
destroy or return all originals and/or copies of documents in any format that contain, reproduce, or
capture Confidential Information. Whether the documents containing Confidential Information are
returned or destroyed, the Receiving Party must submit a written certification to the Producing
Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that
certifies that the Receiving Party has not retained any copies, abstracts, compilations, summaries
or any other format reproducing or capturing any Confidential Information. Notwithstanding this
provision, counsel of record are entitled to retain an archival copy of all pleadings, motion papers,
trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial
exhibits, expert reports, attorney work product, and consultant and expert work product, even if
such materials contain Confidential Information. Any such archival copies that contain or
constitute Confidential Information remain subject to this Protective Order.
This Protective Order shall survive the termination of the lawsuit.
SO ORDERED this ___ day of ___	February	________________, 2026.
/s/ Leslie A. Gardner
11th
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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
ALBANY DIVISION
JOSE RAUL BRIONES, JR.,
Plaintiff,
)
)
)
)
v. 	) 	Case No. 1:24-CV-00082 (LAG)
TAURUS INTERNATIONAL
MANUFACTURING, INC.,
TAURUS HOLDINGS, INC.;
Defendants.
)
)
)
)
)
)
)
EXHIBIT A
ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
I , _____________________________ [print or type full name], of _________________
_____________________________________________________[print or type full address],
declare under penalty of perjury that I have read in its entirety and understand the Stipulated
Protective Order (the “Protective Order”) that was issued by the United States District Court for the
Middle District of Georgia in the above-captioned case. I agree to comply with and to be bound by
all the terms of the Protective Order. I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I agree that I will not disclose in
any manner any information or item that is subject to the Protective Order to any person or entity
except in strict compliance with the provisions of this Protective Order. And I agree not to use any
information designated as Confidential Information that was disclosed to me pursuant to the
Protective Order, except for purposes of the above-captioned litigation.
I further agree to submit to the jurisdiction of the United States District Court for the Middle
District of Georgia for the purpose of enforcing the terms of the Protective Order. I agree to
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accept service of process in connection with this action or any proceedings related to enforcement
of the Stipulated Protective Order by certified letter, return receipt requested, at my principal
residence, in lieu of personal service or other methods of service.
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
Case 1:24-cv-00082-LAG Document 37 Filed 02/11/26 Page 21 of 21