Non-parties Pat Bainter, Matt Mitchell, Michael Sheehan, and DataTargeting, Inc. (collectively “Non-parties”), by and through undersigned counseland pursuant to Rules 1.280 and 1.410, Fla. R. Civ. P., U.S. Const. Amend. I, and Art. I, Sec. 23, Fla. Const., move this Court for a protective order, request an incamera review, and provide a privilege log. In support thereof, Non-parties state:
BACKGROUND AND FACTS
Non-party Pat Bainter is the owner and president of Data Targeting, Inc., a political affairs consulting firm based in Gainesville, Florida. Data Targetingoffers a comprehensive suite of consulting services to various entities whoseinterests and operations are likewise politically oriented, including but not limited to prospective candidates, elected officials, associations and interests groups, political advisors, media organizations, and various corporations and businesses.Guided by decades of research and analysis, Data Targeting assists these entitieswith general campaign strategy, candidate consulting, issue and opinion polling,electorate and public relations, research and record identification, data analysis and mapping, graphic design, direct mail production, and other contracted services.Data Targeting’s consulting operation is rooted in a proprietary foundation of database management, opposition research, and strategic analysis of politicaltrends, electoral demographics, voter performance, and other stakeholder data sets.