ence 1. The role of protective orders in civil litigation. Protective orders serve a "vital function" in civil litigation. Martindell v. Int'l Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote "the `secure the just, speedy, and inexpensive determination' of civil disputes, by encourag

etermination' of civil disputes by encouraging full disclosure of all evidence that might conceivably be relevant." Martindell v. International Tel. & Tel. Corp., 594 F.2d 291, 295 (2d Cir.1979). Unless protective orders are "fully and fairly enforceable," persons relying upon such orders will be inhi

ilege at trial to either submit to discovery on that subject or be precluded from relying on the privileged evidence at trial. See, e.g., Intl Tel. & Tel. Corp. v. United TeL Co. of Fla., 60 F.R.D. 177, 186 (M.D. Fla. 1973) ("Fundamental fairness and justice requires that if the defendant intends to w