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'Under [the discovery] rules, the presumption is that the responding party must bear the expense of complying with discovery requests, but [it] may invoke the district court's discretion under Rule 26(c) to grant orders protecting [it] from 'undue burden or expense' in doing so, including orders conditioning discovery on the requesting party's payment of the costs of discovery.' Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 358, 57 L. Ed. 2d 253, 98 S. Ct. 2380 (1978). 

 Rule 26(c) authorizes courts, for good cause, to 'make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including . . . that certain matters not be inquired into, or that the scope of the disclosure or discovery be limited to certain matters . . . ' Fed.R.Civ.P. 26(c). '[T]he burden is upon the party seeking non-disclosure or a protective order to show good cause.' Dove v. Atlantic Capital Corp., 963 F.2d 15, 19 (2d Cir.1992) (citations omitted).

Good cause for a protective order is demonstrated by the party establishing a 'clearly defined and serious injury shown with specificity' that will result without the ...

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