General Motors, LLC v. Buchanan

Georgia Supreme Court held that trial court failed to properly consider whether a corporate executive’s high rank, the executive’s lack of unique personal knowledge of relevant facts, and the availability of information from other sources demonstrated good cause for a protective order from a deposition, but declines to hold that good cause is presumptively or conclusively established by those factors.  The U.S. Chamber filed an amicus brief supporting consideration of these factors under the apex doctrine.