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