E REQUIRED TO APPEAR FOR DEPOSITION MORE THAN ONCE The district court has discretion to fashion a protective order under Fed.R.Civ.P. 26(c). Farnsworth v. Procter & Gamble Co., 758 F.2d 1545 (11th Cir. 1985). This discretion “does not depend upon a legal privilege.” Id.; Auto Owners Ins. Co. v. So

--- 13 v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (1

overy appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (11th Cir. 1985)(the Federal Rules of Civil Procedure "strongly favor full discovery whenever possible

07) (internal quotations omitted). The Federal Rules of Civil Procedure are broadly written and "strongly favor full discovery whenever possible." Farnsworth I Procter and Gamble Co., 758 F.2d 1545, 1547 (11th Cir.1985). Thus, as this Court has previously ruled in this case, the bottom line is that "[d]is

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Fistos & Lehrman BATES DATE LQ FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Macys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid

Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Seth Lehrman Bradley Edwards Farnsworth v. Marys case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evid