Vendors retained by or for the parties to assist in preparing for pretrial discovery, trial and/or hearings including, but not limited to, court reporters, litigation support personnel, jury consultants, individuals to prepare demonstrative and audiovisual aids for use in the courtroom or in depositions or mock jury sessions, as well as their staff, stenographic, and clerical employees whose duties and responsibilities require access to such materials; and,

Counsel for the designating party or non-party shall respond in writing to such objection within 14 days, and shall state with particularity the grounds for asserting that the document or information is Confidential or Attorneys’ Eyes Only.

The production of any information, document, or thing in this litigation shall not constitute a waiver of any attorney-client privilege or work-product 4890-5336-4880.1 protection that may be asserted by the producing party either in this case or in any other federal or state proceeding.

Upon final conclusion of this litigation, each party or other individual subject to the terms hereof shall be under an obligation to assemble and to return to the originating source all originals and unmarked copies of documents and things containing Confidential or Attorneys’ Eyes Only material or to destroy all copies of such material that contain and/or constitute attorney work product as well as excerpts, summaries and digests revealing Confidential or Attorneys’ Eyes Only material; provided, however, that counsel may retain complete copies of all transcripts and court filings, including any exhibits attached thereto, for archival purposes, subject to the provisions of this Confidentiality Order, with the exception that counsel may not retain PHI.

No later than the final conclusion of the case, I will return all Confidential or Attorneys’ Eyes Only material and summaries, abstracts, and indices thereof which come into my possession, and documents or things which I have prepared relating thereto, to counsel for the party for whom I was employed or retained.

THIS MATTER having come before the Court on October 18, 2023 for a Zoom Case Management Conference to address Defendants’ joint application to stay discovery pending the outcome of their Motions to Dismiss, (ECF Nos. 110); and the Court having considered the parties’ respective submissions in support of and in opposition to the application to stay, (ECF No. 110, 111 and 113); and for the reasons set forth on the record; and for good cause shown, Defendants’ application to stay discovery pending the outcome of their Motions to Dismiss is DENIED; and the Court having conducted a Zoom Initial Scheduling Conference immediately thereafter, and for good cause shown: IT IS on this 18th day of October 2023,

Counsel shall confer in a good faith attempt to informally resolve any and all discovery disputes before seeking the Court’s intervention.

The parties should confer and submit any proposed order relating to the non-waiver or privilege through inadvertent disclosure, pursuant to Federal Rule of Evidence 502(d), on or before December 4, 2023, if needed.

Any disputes over the entry of a discovery confidentiality order should be raised with the Undersigned pursuant to Local Civil Rule 37.1 following a good faith effort to meet and confer.

In cases involving insurance companies and other corporate or business entities, it is expected that the executive who will make the final decision on the settlement will be the person available for the conference.

Case 4:17-cr-00514 Document 546 Filed on 10/17/23 in TXSD Page 1 of 1 United States District Court Southern District of Texas

The Pretrial Services office is ordered to return Elsa Murta’s Portuguese passport to her, upon her request, on October 20, 2023.

When Elsa Murta returns to the United States after that date, she must surrender her Portuguese passport again to the Pretrial Services office by the next business day following her travel.

SIGNED on October 17, 2023, at Houston, Texas.

Kenneth M. Hoyt United States District Judge