used for any purpose except the preparation and trial of this case.””); see also, e.g., Taylor v. Teledyne Techs., Inc., 338 F. Supp. 2d 1323, 1343 (N.D. Ga. 2004) (publicly summarizing and paraphrasing confidential documents violated protective order even without verbatim disclosure). This is especially

plaint, not just to the claims that are the subject of the motion"); Schwartz v. Berry College, Inc., No. Civ.A. 4:96CV338-HLM, 1997 WL 579166, *l (N.D. Ga. July 3, 1997) (noting that there is significant case law to support the position that "when a defendant files a Rule 12(b) motion to dismiss, addres

rd for dismissal under Rule 12(b)(6) in the typical case. See, e.g., CBT Flint Partners, LLC v. Goodmail Systems, Inc., 529 F.Supp. 2d 1376, 1379 (N.D. Ga. 2007); Coughlin v. Wal-Mart Stores East LP, 2008 WL 2704381 (M.D. Fla. 2008); Capaz v. Whitaker, Weinstraub & Grizzard, M.D.S, P.A., 2007 WL 165547

d based new license for federal courts to ramp up pleading requirements. CBT Flint Partners, LLC v. Goodmail Systems, Inc., 529 F.Supp.2d 1376, 1379 (N.D. Ga. 2007). In this case, Defendant contends that the pleadings fail to allege the specific facts of “what was said or done to Plaintiff;” “what Epstein s

5 of 6 6 Fla. 1990)(reminding the parties that “discovery should be conducted extrajudicially”); Knight v. Docu-Fax, Inc., 838 F.Supp. 1579, 1581 (N.D. Ga. 1993)(“[the Federal Rules of Civil Procedure] contemplate that discovery be conducted with a minimum of judicial intervention”). The Court will, of c

privilege also extends to subordinates of a party's attorney. -- - - - - - ··- --·· -· -- . -- See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege is ... a client; (2) the

was not at all involved in either the investigation or the prosecution of the defendants"); United States v. Battle, 264 F. Supp. 2d 1088, 1201-02 (N.D. Ga. 2003) ("Defendant implies that because the BOP employees are connected with the Department of Justice that the prosecution team constructively poss