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Old 05-14-2016, 12:14 PM   #1766
Icky Thump
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Join Date: Jun 2007
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Re: No Faith in the Moral Standards of the Players as a Group

Quote:
Originally Posted by Not Bob View Post
I'm with Icky - it's really amazing how often "it depends" is the correct answer.

Is Company B a party to the case with the protective order? Does the PO say anything about use of eyes only docs at depos?

In the past, I've either said something like "did you send an email to Sidd Finch about 2nd quarter 2014 widget pricing?" (after setting it up with general questions about whether B's CEO communicated with anyone), or went thru the PO process of removing the eyes only designation on multiple documents (so as not to tip my hand on the ones I really want to use).

Good luck.
I assumed that but this brings up another good point. I agreed to exactly one protective order but made it so that I could use the documents in any subsequent related litigation against the same company by any other plaintiff I represented.
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