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    United States District Court District of Massachusetts Springfield Division

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    Equality Case Files
    Doc 153 - Proposed Order on Motion to Amend

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    United States District Court District of Massachusetts Springfield Division

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    Equality Case Files
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    Doc 153 - Proposed Order on Motion to Amend

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    3:12-cv-30051 #153

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    Doc 153 - Proposed Order on Motion to Amend

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    169 views2 pages

    United States District Court District of Massachusetts Springfield Division

    Uploaded by

    Equality Case Files
    Doc 153 - Proposed Order on Motion to Amend

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 2

    Case 3:12-cv-30051-MAP Document 153 Filed 05/04/15 Page 1 of 2

    UNITED STATES DISTRICT COURT


    DISTRICT OF MASSACHUSETTS
    SPRINGFIELD DIVISION

    SEXUAL MINORITIES UGANDA,


    Plaintiff,
    CIVIL ACTION
    v.
    NO. 3-12-CV-30051-MAP
    SCOTT LIVELY, individually and as President of
    Abiding Truth Ministries,
    Defendant.
    [PROPOSED] ORDER GRANTING PLAINTIFFS MOTION TO AMEND
    THE ORDER REGARDING CONFIDENTIALITY OF CERTAIN
    DISCOVERY MATERIAL
    This cause, having come before the Court upon Plaintiff Sexual Minorities Ugandas
    Motion to Amend the Order Regarding Confidentiality of Certain Discovery Materials (Dkt. No.
    106) (the Protective Order) so that Plaintiff may designate certain exceptionally sensitive
    documents for Attorneys Eyes Only protection (the Motion), and the Court, being otherwise
    duly advised, hereby GRANTS such Motion.
    The Court hereby amends the Protective Order to provide as section 18:
    18(a). Attorneys Eyes Only. Any party may designate material
    ATTORNEYS EYES ONLY if such material concerns: (a) the safety
    and security needs of LGBTI people in Uganda in the wake of the passage
    of the Anti-Homosexuality Act; (b) security assistance to a health clinic
    for the LGBTI community in Uganda; (c) communications with
    representatives of international governments concerning the persecution
    and the safety and well-being of LGBTI persons in Uganda; or (d)
    documents concerning a February 2012 raid on a workshop attended by
    LGBTI persons in Uganda. Attorneys Eyes Only information and
    documents may include documents, portions of deposition transcripts,
    interrogatory answers, responses to requests for admission, and any other
    discovery materials designated as ATTORNEYS EYES ONLY. Access

    Case 3:12-cv-30051-MAP Document 153 Filed 05/04/15 Page 2 of 2

    to Discovery material designated by the producing party as


    ATTORNEYS EYES ONLY pursuant to this Order shall be limited to
    counsel of record, including members or associates of such counsels firm,
    as well as their legal interns, paralegals, and secretarial and clerical
    personnel who are engaged in assisting such counsel in this Action, and to
    consulting and testifying experts. Material designated by the producing
    party as ATTORNEYS EYES ONLY may not be disclosed, in whole or
    in part, to counsel of records client, the requesting party.
    18(b). Protection of Attorneys Eyes Only During Depositions. During the
    deposition of any witness, questions which directly pertain to information
    designated as Attorneys Eyes Only or questions that reasonably could
    lead to discussion of information designated as Attorneys Eyes shall be
    reserved for a closed portion of the deposition. During such closed
    portion of the deposition, only the witness, attorneys, and court reporter
    may be present in the deposition room; all others must leave, including
    any parties. Should a question during the unrestricted portion of the
    deposition threaten the appropriate handling of Attorneys Eyes Only
    information, counsel may object and the question may be reserved for the
    closed portion. Following the deposition, the entire transcript and any
    video or audio footage shall be kept under the Attorneys Eyes Only
    designation for a minimum of thirty days, during which time specific lines
    of the transcript may be designated as subject to Attorneys Eyes Only
    protection through clearly written designations of ATTORNEYS EYES
    ONLY. Video footage will be considered Attorneys Eyes Only based
    upon designations correlating with the marked lines of the transcript. Until
    the end of this review period, all transcripts, audio, and video recordings
    will be held, labeled, and stored as if they are, in their entirety, Attorneys
    Eyes Only information. Any disputes over which information is
    designated Attorneys Eyes Only must be addressed within five business
    days of the receipt of the designated materials, else no objections will be
    considered.

    IT IS SO ORDERED.
    DATED: ______________, 2015
    ____________________________________
    The Honorable Katherine A. Robertson
    United States Magistrate Judge

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