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Other Statutory Actions | Massachusetts
Protective Order
Judge Indira Talwani: PROTECTIVE ORDER (Attachments: # 1 Exhibit A) (MAP)
Order ~Util - Terminate Motions
Judge Indira Talwani: ELECTRONIC ORDER granting in part and denying in part Petitioner Grupo Gayosso, S.A. de C.V.’s (“Gayosso”) Emergency Motion for Entry of Protective Order [ 32 ] (“Gayosso’s Motion”) and Respondent Advent International Corporation’s (“AIC”) Motion for Entry of Protective Order [ 33 ] (“AIC’s Motion”)On June 30, 2026, the court granted in part and denied in part Gayosso’s Application for an Order Pursuant to 28 U.S.C. § 1782 to Conduct Discovery for Use in a Foreign Proceeding [ 1 ] (“Application”). The court ordered that “Gayosso may serve the Subpoena [[1-5]], but shall limit Schedule A [of the Subpoena] to exclude the WhatsApp communications[.]” Mem. & Order 11 [ 31 ]. The court ordered further that the parties should submit a proposed protective order for this court’s consideration. Id. The parties now dispute the scope of the production responsive to the subpoena. AIC contends that this order limited the required production to the pages identified by Bates-stamp number in Schedule A of Gayosso’s Proposed Subpoena. See AIC’s Mem. of Law Ex. A, ¶ 1.a [[34-1]] (“AIC’s [Proposed] Stipulated Protective Order”) (“‘Documents’ means the document ordered produced by the Order, as listed in Exhibit B.”); see also id. at 17 (listing documents by Bates-stamp number); AIC’s Mem. of Law 3 [ 34 ] (asserting that “Gayosso... informed AIC for the first time that it intended to subpoena documents beyond those sought in its [§] 1782 petition... [and] stated an intention to add nearly 200 documents beyond those listed by Bates number in docket 1-5.”). Gayosso meanwhile asserts that the listed Bates number on Schedule A referred to “the first page of each document family for which it sought production.” Gayosso’s Mot. ¶ 3 [ 32 ]. Gayosso’s Application [ 1 ] sought discovery “set forth in the proposed subpoena and Schedule A thereto[.]” Id. at ¶ 2. Schedule A provided that “[i]f any part of a document is responsive to a Request, the document in its entirety must be produced, including all attachments and enclosures. Documents attached to each other shall not be separated.” Application Ex. A, at ECF 9 [[1-5]]. Where Schedule A specifically referenced entire documents and their attachments, and AIC has offered no grounds not previously considered by the court other than AIC’s surprise that Gayosso sought complete documents and attachments and not merely the first page of each document, AIC’s objection is overruled. The parties also were unable to reach agreement on a proposed protective order. Gayosso objects that AIC is seeking an end-run around the court’s order by requiring, prior to the submission of any documents subject to the subpoena, that the Mexican court have entered an order of confidentiality. Gayosso’s Motion ¶ 1 [ 32 ]. Gayosso objects further that AIC is seeking execution of Agreements to be Bound by multiple individuals, to be filed with the court, in advance of Mexican counsel’s receipt of documents, thereby ensuring that counsel would not have time to review and submit the documents by July 7, 2026. Id. ¶ 2. AIC asserts that such protections are necessary and should mirror the limitations of the Amended Protective Order in Servicios Funerarios GG., S.A. de C.V. v. Advent International Corp., No. 1:21-cv-11236-IT (D. Mass.). AIC’s Mem. of Law 4–5 [ 1103 additional result(s)
On June 30, 2026, the court granted in part and denied in part Gayosso’s Application for an Order Pursuant to 28 U.S.C. § 1782 to Conduct Discovery for Use in a Foreign Proceeding [ 1 ] (“Application”). The court ordered that “Gayosso may serve the Subpoena [[1-5]], but shall limit Schedule A [of the Subpoena] to exclude the WhatsApp communications[.]” Mem. & Order 11 [ 31 ]. The court ordered further that the parties should submit a proposed protective order for this court’s consideration. Id.
The parties now dispute the scope of the production responsive to the subpoena. AIC contends that this order limited the required production to the pages identified by Bates-stamp number in Schedule A of Gayosso’s Proposed Subpoena. See AIC’s Mem. of Law Ex. A, ¶ 1.a [[34-1]] (“AIC’s [Proposed] Stipulated Protective Order”) (“‘Documents’ means the document ordered produced by the Order, as listed in Exhibit B.”); see also id. at 17 (listing documents by Bates-stamp number); AIC’s Mem. of Law 3 [ 34 ] (asserting that “Gayosso... informed AIC for the first time that it intended to subpoena documents beyond those sought in its [§] 1782 petition... [and] stated an intention to add nearly 200 documents beyond those listed by Bates number in docket 1-5.”). Gayosso meanwhile asserts that the listed Bates number on Schedule A referred to “the first page of each document family for which it sought production.” Gayosso’s Mot. ¶ 3 [ 32 ].
Gayosso’s Application [ 1 ] sought discovery “set forth in the proposed subpoena and Schedule A thereto[.]” Id. at ¶ 2. Schedule A provided that “[i]f any part of a document is responsive to a Request, the document in its entirety must be produced, including all attachments and enclosures. Documents attached to each other shall not be separated.” Application Ex. A, at ECF 9 [[1-5]]. Where Schedule A specifically referenced entire documents and their attachments, and AIC has offered no grounds not previously considered by the court other than AIC’s surprise that Gayosso sought complete documents and attachments and not merely the first page of each document, AIC’s objection is overruled.
The parties also were unable to reach agreement on a proposed protective order. Gayosso objects that AIC is seeking an end-run around the court’s order by requiring, prior to the submission of any documents subject to the subpoena, that the Mexican court have entered an order of confidentiality. Gayosso’s Motion ¶ 1 [ 32 ]. Gayosso objects further that AIC is seeking execution of Agreements to be Bound by multiple individuals, to be filed with the court, in advance of Mexican counsel’s receipt of documents, thereby ensuring that counsel would not have time to review and submit the documents by July 7, 2026. Id. ¶ 2. AIC asserts that such protections are necessary and should mirror the limitations of the Amended Protective Order in Servicios Funerarios GG., S.A. de C.V. v. Advent International Corp., No. 1:21-cv-11236-IT (D. Mass.). AIC’s Mem. of Law 4–5 [ 1103 additional result(s)
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