Protective Orders Regarding Confidential Info

The definition of "document," as in a request for production of documents, includes electronic data. See, e.g., Fed. R. Civ. P. 34(a) (a request for production of documents includes data compilations); Simon Property Group, L.P. v. mySimon, Inc., 194 F.R.D. 639, 640 (S.D. Ind. 2000) (holding that "computer records, including records that have been 'deleted,' are documents discoverable under Fed. R. Civ. P. 34); Playboy Enterprises, Inc. v. Welles, 60 F. Supp. 2d 1050, 1053 (S.D. Cal. 1999) (granting plaintiff access to defendant's hard drive in order to obtain "deleted" e-mails).

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