failing to seek a confidentiality order at the time of production, waived their right to seek a confidentiality order after production, but before the IAU Report was published. As a starting point, Rule 26(c) makes no mention of a timeliness requirement for seeking a protective order — although its pre-1970 predecessor required that requests for protective orders be made “seasonably”. See Fed.R.Civ.P. 30(b), 48 F.R.D. 487, 510 (1970). Nevertheless, several courts have held that Rule 26(c) implicitly requires parties to request a protective order at the time of production, and provides that a failure to do so permanent- ly waives the right to such an order. See, e.g., Schiller v. City of New York, Nos. 04-cv-7922 & 04-cv-7921, 2007 WL 136149, *5 (S.D.N.Y. Jan. 19, 2007) (Francis, M.J.) (<HOLDING>); Brittain v. Stroh Brewery Co., 136 F.R.D.
holding that a claim for ineffective assistance of counsel waives attorneyclient privilege holding that production of documents without a claim of privilege waives the right to later claim that privilege holding that a claim of privilege to bank records pursuant to federal public policy was without merit recognizing privilege holding that an invocation of the advice of counsel defense waives the attorneyclient privilege