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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 20-cv-22885-Williams/Torres

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PAYCARGO, LLC,

Plaintiff, 

-againstPAVEL GALBREATH aka

PASHA GALBREATH aka

PASHA PROBIV, WALE UP LLC and

CARGOSPRINT LLC

Defendant.

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[PROPOSED] STIPULATED PROTECTIVE ORDER

Whereas, Plaintiff PayCargo, LLC (“Plaintiff”), and Defendants Pavel Galbreath a/k/a 

Pasha Galbreath a/k/a Pasha Probiv, Wale Up LLC, and CargoSprint LLC (collectively 

“Defendants”) (all hereafter, the “Parties to this Action”), believe that certain information that is or 

will be encompassed by discovery demands by the Parties to this Action involves the production or 

disclosure of trade secrets, confidential business information, and/or other proprietary information;

Whereas, the Parties to this Action seek a protective order limiting disclosure thereof in 

accordance with Federal Rules of Civil Procedure 26(c);

Therefore, it is hereby stipulated among the Parties to this Action and, for good cause

shown, the following is ORDERED:

1. Scope. All documents (including electronically stored information) produced in the 

course of discovery, including responses to discovery requests, all deposition testimony and 

exhibits, documents produced by third parties subject to subpoena, other materials which may be 

subject to restrictions on disclosure for good cause, and information derived directly therefrom 

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(hereinafter collectively “documents”), shall be subject to this Order concerning confidential 

information as set forth below. The Order is also subject to the Local Rules of this Court and the 

Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

2. Form and Timing of Designation. Any party or third party responding to a 

subpoena or other discovery request, including a request for production of documents, may 

designate documents as confidential and restricted in disclosure upon making a good faith

determination that the documents contain information protected from disclosure by statute or that

should be protected from disclosure as confidential personal information, medical information,

proprietary business information, trade secrets, personnel records, or such other sensitive

commercial information that is not publicly available under this Order, by placing or affixing

the word “CONFIDENTIAL” on the document in a manner that will not interfere with the

legibility of the document, or, if that is not possible, by placing the document in a container which 

prominently states “CONFIDENTIAL” or including the word “CONFIDENTIAL” in the name of 

an electronic file. Any party or third-party responding to a subpoena or other discovery request, 

including a request for production of documents, may also designate documents as

“ATTORNEYS’ EYES ONLY” for such materials as it (A) reasonably and in good faith believes

to contain particularly sensitive information relating to research for and production of products or 

services; technical, business, and research information regarding future products or services; nonpublic and highly sensitive financial information; marketing and sales information, such as 

marketing plans and forecasts, customer lists, pricing data, cost data, vendor, talent or supplier lists 

and communications with vendors, talent or suppliers and financial information relating to same;

or such other documents, information, or materials that relate to other proprietary information; and

(B) reasonably and in good faith believes that public revelation of the information would cause

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competitive injury to the producing party. Documents shall be designated “CONFIDENTIAL” or

“ATTORNEYS’ EYES ONLY” prior to or at the time of the production or disclosure of the 

documents. The designation “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” does not

mean that the document has any status or protection by statute or otherwise except to the extent 

and for the purposes of this Order.

3. Documents Which May be Designated “CONFIDENTIAL” Or 

“ATTORNEYS’ EYES ONLY.” Any party or third party in response to a subpoena or other 

discovery request, including a request for production of documents, may designate documents as

“CONFIDENTIAL” upon making a good faith determination that the documents contain

information protected from disclosure by statute or that should be protected from disclosure as

confidential personal information, medical information, proprietary business information, trade

secrets, personnel records, or such other sensitive commercial information that is not publicly 

available. Any party or third party in response to a subpoena or other discovery request, including 

a request for production of documents, may designate as “ATTORNEYS’ EYES ONLY” such 

materials as it (A) reasonably and in good faith believes to contain particularly sensitive

information relating to research for and production of products or services; technical, business,

and research information regarding future products or services; non-public and highly sensitive

financial information; marketing and sales information, such as marketing plans and forecasts,

customer lists, pricing data, cost data, vendor, talent or supplier lists and communications with 

vendors, talent or suppliers and financial information relating to same; or such other documents,

information, or materials that relate to other proprietary information; and (B) reasonably and in

good faith believes that public reveal of the information cause competitive injury to the producing

party.

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Public records or other information or documents that are publicly available in the form in 

which they are possessed by the Parties to this Action may not be designated as 

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”

4. Depositions. Deposition testimony shall be deemed “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” only if designated as such. Such designation shall be specific as 

to the portions of the transcript or any exhibit to be designated as “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY.” Thereafter, the deposition transcripts and any of those portions 

so designated shall be protected as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” 

pending objection, under the terms of this Order. Deposition testimony (even where not yet 

transcribed) and any accompanying exhibits shall be deemed “ATTORNEYS’ EYES ONLY” prior 

to transcription and for a period of fourteen (14) calendar days after the transcription of said

deposition, but said designation will expire at the conclusion of that fourteen-day period unless

Defendants or Plaintiff designate portions of said testimony as “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” by letter or e-mail to the other parties.

5. Protection of “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” 

Material.

a. General Protections. Documents designated “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” under this Order shall not be used or disclosed

by the Parties to this Action, counsel for the Parties to this Action, or any other

person identified in Paragraph 5(b) for any purpose whatsoever other than to

prepare for and to conduct discovery, hearings, and trial in this action, including

any appeal thereof.

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b. Limited Third-Party Disclosures. The Parties to this Action and counsel for the

Parties to this Action shall not disclose or permit the disclosure of any

“CONFIDENTIAL” documents to any third person or entity except as set forth

in section 5(b) subparagraphs (1), (2), (4), (5), and (6), and counsel for the Parties

to this Action shall not disclose or permit the disclosure of any “ATTORNEYS’

EYES ONLY” documents to any third person or entity except as set forth in

section 5(b) subparagraphs (1), (3), (4), (5), and (6). Subject to these requirements,

the following categories of persons may be allowed to review documents that have 

been designated “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”

1. Counsel. Outside counsel for the Parties to this Action and employees and

agents of counsel who have responsibility for the preparation and trial of

the action or related actions;

• In-House Counsel. Pursuant to his sworn representation that he is 

not involved in competitive-decision making activities for Plaintiff, 

Plaintiff’s in-house counsel, Jason H. Weber, Esq. shall have access 

to “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” 

information and documents under the terms of this Protective 

Order, excluding, however, information and documents in the 

following categories which shall be further designated “NOT FOR 

IN-HOUSE COUNSELS’ EYES”:

- computer code, including source code which shall 

be defined as follows: 

Source code is considered to be all code in the 

entities’ formal or informal software code 

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repositories including but not limited to 

developer or engineer computer systems, file or 

data storage locations, external storage devices, 

cloud or other third party storage locations or 

software code repositories, email, or any location 

where developers, engineers, or other individuals 

having access to the software code may have 

stored or copied software code. The scope of 

source code shall include software code, scripts, 

documentation and other materials providing 

functionality and support to the applications, 

databases, user-interface design and 

implementation, and other systems including 

APIs.

- access to the CargoSprint platform;

- information regarding money flows in the 

CargoSprint platform;

- customer, vendor or supplier lists;

- pricing information; and

- negotiations with customers, vendors, or suppliers.

No other in-house counsel for any of the parties shall have access 

to “ATTORNEYS’ EYES ONLY” information or documents. In 

the event a disclosing party become aware of other categories of 

information that should be excluded from Mr. Weber’s access, the 

parties shall cooperate in good faith to revise the above list.

2. Parties. Parties to this Action and employees of a party subject to this 

Order, other than In-House Counsel, except that:

• Defendant Pavel Galbreath a/k/a Pasha Galbreath a/k/a Pasha Probiv

(“Galbreath”), now represented by legal counsel, shall have access 

to “CONFIDENTIAL” information and documents under the terms 

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of this Protective Order, excluding, however, information and 

documents in the following categories which shall be further 

designated “NOT FOR GALBREATH’S EYES”:

- computer code, including source code which shall 

be defined as follows:

Source code is considered to be all code in the 

entities’ formal or informal software code 

repositories including but not limited to developer or 

engineer computer systems, file or data storage 

locations, external storage devices, cloud or other 

third party storage locations or software code 

repositories, email, or any location where 

developers, engineers, or other individuals having 

access to the software code may have stored or 

copied software code. The scope of source code shall 

include software code, scripts, documentation and 

other materials providing functionality and support 

to the applications, databases, user-interface design 

and implementation, and other systems including 

APIs.

- access to the PayCargo platform;

- information regarding money flows in the PayCargo 

platform;

- customer, vendor or supplier lists;

- pricing information; and

- negotiations with customers, vendors, or suppliers.

In the event a disclosing party becomes aware of other categories 

of information that should be excluded from Mr. Galbreath’s 

access, the parties shall cooperate in good faith to revise the above 

list.

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3. Limited Purpose Party Representatives. If counsel believes in good faith 

that it is necessary to disclose any ATTORNEYS’ EYES ONLY material 

to a client representative in order to receive context or information 

regarding the relevance or meaning of the ATTORNEYS’ EYES ONLY

material—in the interest of efficiently litigating the matter—counsel shall 

do the following:

• Identify a client representative that counsel determines would be 

able to provide the desired context or information regarding the 

specific material;

• Ask opposing counsel if they consent to disclosure of the specific 

ATTORNEYS’ EYES ONLY material to the designated client 

representative. If opposing counsel consents, the designated client

representative must sign the “Agreement To Be Bound By 

Stipulated Protective Order,” attached hereto as Attachment A, 

before the ATTORNEYS’ EYES ONLY material may be disclosed 

to the client representative;

• If opposing counsel does not consent, counsel shall schedule a 

status conference with the Court, at which time the Court will 

determine whether the ATTORNEYS’ EYES ONLY material may 

be disclosed to the identified client representative.

4. Court Reporters, Interpreters, and Recorders. Court reporters, 

interpreters, videographers, stenographers, and recorders engaged for

depositions;

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5. Consultants, Investigators and Experts. Consultants, investigators, or

experts (hereinafter referred to collectively as “experts”) employed by the

Parties to this Action or counsel for the Parties to this Action to assist in the

preparation and trial of this action or proceeding, but only aftersuch persons 

have completed the certification contained in Attachment A, Agreement to 

be Bound by Stipulated Protective Order.; and

6. Others by Consent. Other persons only by written consent of the 

producing party or upon order of the Court and on such conditions as may

be agreed or ordered. All such persons shall execute the certification

contained in Attachment A, “Agreement to be Bound by Stipulated 

Protective Order.”

c. Control of Documents. Counsel for the Parties to this Action shall take

reasonable and appropriate measures to prevent unauthorized disclosure of 

documents designated as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY”

pursuant to the terms of this Order. Counsel shall maintain the originals of the 

forms signed by persons acknowledging their obligations under this Order for

a period of one (1) year after dismissal of the action, the entry of final judgment 

and/or the conclusion of any appeals arising therefrom.

6. Source Code. Any source code produced in discovery as “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” shall be made available in a format allowing it to be 

reasonably reviewed and searched. Review of the source code shall occur on a secured 

computer that is not connected to the internet and is not connected to other computers that 

are connected to the internet, and the person reviewing such material shall not copy, 

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remove, or otherwise transfer any portion of the source code onto any recordable media or 

recordable device. The person reviewing such material may request paper copies of 

limited portions of source code that are reasonably necessary for the preparation of court 

filings, pleadings, expert reports, or other papers, or for deposition or trial. The 

designating party shall provide all such source code in paper form including bates numbers 

and, if applicable, the label “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” The 

designating party may challenge the amount of source code requested in hard copy form 

pursuant to the dispute resolution procedure and timeframes set forth herein. The person 

to whom such material is produced shall maintain a record of any individual who has 

inspected any portion of the source code in electronic or paper form. The person to whom 

such material is produced shall maintain all paper copies of any printed portions of the 

source code in a secured, locked area. The person to whom such material is produced shall 

not create any electronic or other images of the paper copies and shall not convert any of 

the information contained in the paper copies into any electronic format. The person to 

whom such material is produced shall only make additional paper copies if such additional 

copies are (1) necessary to prepare court filings, pleadings, or other papers (including a 

testifying expert’s expert report), (2) necessary for deposition, or (3) otherwise necessary 

for the preparation of its case. Any paper copies used during a deposition shall be retrieved 

by the designating party at the end of each day and must not be given to or left with a court 

reporter or any other unauthorized individual. However, any deposition exhibits that 

include paper copies of source code shall be marked as exhibits for the record, and copies 

of such exhibits shall be securely maintained by counsel for the parties.

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7. Inadvertent Production. The inadvertent production of any document or 

information during discovery in this action shall be without prejudice to any claim that such 

material is privileged under the attorney-client privilege, work-product doctrine, or any other 

legally recognized privilege, or constitutes trade secrets, and no party shall be held to have waived

any rights by such inadvertent production, so long as the inadvertently producing party notifies the 

receiving party within a reasonable time. Upon timely written request by the inadvertently 

producing party, the receiving party shall (1) return or sequester the original and all copies of such

documents and (2) shall not use such information for any purpose unless allowed by Order of the

Court.

If any document or information is inadvertently produced without a designation of 

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” the party or third party responding to a 

subpoena that inadvertently produced the document or information without the appropriate 

designation may notify the party or parties that received the document or information and instruct 

any receiving party to promptly return, sequester, or destroy the specified document or information 

and any copies it may have. The party or third party responding to a subpoena or other discovery 

request, including a request for production of documents, must reproduce the document(s) with

the appropriate designation of “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” Any party 

that receives any document or information that was inadvertently produced without a designation

of “CONFIDENTIAL” or “ATTORNEYS’EYES ONLY,” and thatreceives timely notice from the

producing party of the inadvertent production, must not use or disclose the document or

information and must take reasonable steps to retrieve the document or information, if the party

disclosed it before being notified of the inadvertent production.

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8. Filing of “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” 

Documents Under Seal. To the extent that a brief, memorandum or pleading references any 

document marked as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY,” then the brief, 

memorandum or pleading shall refer the Court to the particular exhibit filed under seal without 

disclosing the contents of any confidential information.

a. This Order does not authorize filing protected materials under seal, except where

expressly provided otherwise. No document may be filed with the Court under seal

without prior permission as to each such filing, upon motion and for good cause

shown, including the legal basis for filing under seal. Unless the Court orders

otherwise, all sealed documents shall be filed according to S.D. Florida L. R. 5.4.

b. If a Party to this Action wishes to file any confidential information with the Court, 

it shall do everything necessary to ensure that such information is impounded, kept 

under seal, and unavailable to the public, including observing all requirements of 

Southern District of Florida Local Rules, including its provisions regarding the 

filing of motions to seal. All “CONFIDENTIAL” or “ATTORNEYS’ EYES 

ONLY” documents and/or information filed with the Court shall be filed in 

accordance with Local Rule 5.4(b) governing the filing of sealed documents.

c. If the Court does not permit the filing under seal of a “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” document, the Parties to this Action shall confer 

in good faith so that the confidentiality of designated documents is preserved at all 

times. If filing of a “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” 

document under seal is ultimately and finally refused by the Court after a motion 

under Local Rule 5.4(b), the document shall not be filed with the Court unless 

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express permission is given by the producing party for such filing. If a document 

or thing produced cannot conveniently be marked as required by this Order, the 

Parties to this Action shall confer and agree in writing on an appropriate way of 

marking or otherwise identifying as “CONFIDENTIAL” or “ATTORNEYS’ 

EYES ONLY” such document or thing.

d. To the extent that it is necessary for a party to disclose or discuss the content of any 

document marked as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” in a

written brief, memorandum or pleading, then the entire written brief,

memorandum or pleading shall be filed under seal upon motion and for good cause

shown, including the legal basis for filing under seal, or redacted in a manner 

sufficient to protect the public disclosure of such information.

9. Challenges by a Party to Designation as “CONFIDENTIAL.” Any

“CONFIDENTIAL” designation is subject to challenge by any party or non-party with standing to 

object (hereinafter “objecting party”). Before filing any motions or objections to a confidentiality 

designation with the Court, the objecting party shall have an obligation to meet and confer in a good 

faith effort to resolve the objection by agreement. If agreement is reached confirming or waiving the 

“CONFIDENTIAL” designation as to any documents subject to the objection, the designating party 

shall serve on all parties a notice specifying the documents and nature of the agreement.

10. Challenges by a Party to Designation as “ATTORNEYS’ EYES ONLY.”

If a party disputes the designation of any material as “ATTORNEYS’ EYES ONLY,” counsel for 

the disputing party shall notify counsel for the producing party. No later than five (5) business

days after receiving that notice, counsel will meet and confer in a good faith effort to resolve the 

dispute. If the parties are unable to resolve their dispute, the objecting party may file a motion

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under seal and submit the disputed material for in camera review, and the party that made the

designation shall file an opposition within five (5) business days thereafter. The Court, at its

discretion, will conduct a telephone status conference to resolve the dispute and may grant relief

that it deems appropriate.

11. Action by the Court. Applications to the Court for an order relating to any 

documents designated “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” shall be by motion

(or by employing the Magistrate’s “discovery calendar” process) and in accordance with any other

proceduressetforth in the presiding judge’sstanding orders or otherrelevant orders. Nothing in this

Order or any action or agreement of a party under this Order limits the Court’s power to make

any orders that may be appropriate with respect to the use and disclosure of any documents 

produced or used in discovery or at trial.

12. Use of “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” Documents 

or Information at Trial/Hearing. All trials/hearings are open to the public. Absent order of the 

Court, there will be no restrictions on the use of any document that may be introduced by any 

party during the trial/hearing. If a party intends to present at trial/hearing “CONFIDENTIAL” or 

“ATTORNEYS’ EYES ONLY” documents or information derived therefrom, such party shall 

provide advance notice to the other party or third party that produced the documents or information

in response to a subpoena or other discovery request, including a request for production of 

documents, at least five (5) business days before the commencement of trial/hearing by identifying

the documents or information at issue as specifically as possible (i.e., by Bates number, page

range, deposition transcript lines, etc.) without divulging the actual “CONFIDENTIAL” or

“ATTORNEYS’ EYES ONLY” documents or information. The Court may thereafter make such

orders as are necessary to govern the use of such documents or information at trial/hearing. No

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such document may be offered into evidence unless the Court has first approved its submission.

The attempted introduction or introduction of such evidence shall be subject to further Order of 

the Court following an in-camera review and hearing arguments of counsel.

13. Obligations Upon Conclusion of Litigation.

a. Order Remains in Effect. Unless otherwise agreed or ordered, this Order shall 

remain in force after dismissal or entry of final judgment not subject to further

appeal and the Court shall retain jurisdiction to hear any disputes arising under this 

Order.

b. Return of “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” 

Documents. One year after dismissal or entry of final judgment not subject to

further appeal, all documents treated as “CONFIDENTIAL” or “ATTORNEYS’

EYES ONLY” under this Order, including all copies, shall be returned to the

producing party or third party, and all electronic copies thereof deleted from the 

receiving party’s records and files, unless: (1) the document has been offered into 

evidence or filed without restriction as to disclosure; (2) the parties agree to 

destruction in lieu of return; (3) any time after entry of final judgment not subject to

further appeal, and prior to the one year period mentioned above, the producing

party requestsin writing the return of the documents; or (4) as to documents bearing 

the notations, summations, or other mental impressions of the receiving party, that

party elects to destroy the documents and certifies to the producing party that it

has done so. Notwithstanding the above requirements to return or destroy 

documents, counsel may retain attorney work-product, including an index which

refers or relates to information designated “CONFIDENTIAL” or “ATTORNEYS’

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EYES ONLY,” so long as that work-product does not duplicate verbatim

substantial portions of the text or images of confidential documents. This workproduct shall continue to be “CONFIDENTIAL” or “ATTORNEYS’ EYES 

ONLY” under this Order. An attorney may use his or her work-product in a

subsequent litigation provided that its use does not disclose or use 

“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” documents.

c. Return of Documents Filed Under Seal. After dismissal or entry of final 

judgment not subject to further appeal, the Clerk may elect to return to counsel for

the Parties to this Action, or, after notice, destroy documents filed or offered at

trial under seal or otherwise restricted by the Court as to disclosure.

14. Order Subject to Modification. This Order shall be subject to modification by 

the Court on its own motion or on motion of a party or any other person with standing concerning 

the subject matter. Motions to modify this Order shall be served and filed under any applicable 

local rule and the presiding judge’s standing orders or other relevant orders.

15. No Prior Judicial Determination. This Order is entered based on the

representations and agreements of the parties and for the purpose of facilitating discovery. Nothing 

herein shall be construed or presented as a judicial determination that any documents or 

information designated “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” by counsel or the 

parties is subject to protection under Rule 26(c) of the Federal Rules of Civil Procedure or 

otherwise until such time as the Court may rule on a specific document or issue. Nor does this 

Order constitute a waiver of any party’s rights to object to discovery on any grounds.

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16. Third Party Discovery. A copy of this order shall accompany (a) any subpoena 

issued to a third party in this case; (b) any other discovery request issued to a third party in this 

case. 

17. Persons Bound. This Order shall take effect when entered and shall be binding 

upon all counsel and their law firms, the parties, and persons made subject to this Order by its 

terms.

IT IS SO ORDERED.

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