Stamps v. Encore Receivable Mgmt., Inc., 232 F.R.D. 419 (N.D. Ga. 2005)

Key Insight: Plaintiff was not entitled to protective order delaying, until after key depositions were taken, production of tape recording of message left by defendant’s representative on plaintiff’s home answering machine, since tape constituted substantive evidence and was not mere impeachment evidence, and issues of fairness weighed in favor of production

Nature of Case: Debtor alleged violations of Fair Debt Collection Practices Act

Electronic Data Involved: Tape recording of message left on answering machine