The opinion of the court was delivered by: DENISE COTE, District Judge
[PROPOSED] CONFIDENTIALITY ORDER
IT IS HEREBY ORDERED that the following provisions of this
Confidentiality Order shall govern disclosure to the undersigned
parties of the terms of the Confidential Schedule to Bar Order
and Order of Dismissal ("Confidential Schedule").
1. The Confidential Schedule shall not be disclosed, directly
or indirectly, to any person other than:
(a) a court of competent jurisdiction and necessary court
(b) the named parties to the above-captioned action;
(c) the named parties' attorneys and partners, associates and
employees of the attorneys' law firms;
(d) in-house attorneys for any named party to the
above-captioned action, regular employees of the in-house legal
department of any named party to the above-captioned action, and
necessary management personnel for any named party to the
above-captioned action; (e) any expert retained or consulted by any party in connection
with the above-captioned action and those working under their
direction or control.
2. Prior to obtaining access to the Confidential Schedule, each
party to the above-captioned litigation shall review the terms
and conditions of this Order and shall execute the Schedule
attached to this Confidentiality Order, agreeing to be bound by
the terms and conditions set forth in this Order governing
disclosure of the Confidential Schedule.
3. All persons, as described in paragraph I above, to whom the
Confidential Schedule is disclosed shall, prior to disclosure, be
advised (a) of the contents of this Order; and (b) that the
Confidential Schedule is being disclosed pursuant to the terms of
this Order and may not be disclosed other than pursuant to the
4. In the event that counsel for any party determines to file
with a court the Confidential Schedule, information derived
therefrom, or any papers containing or making reference to such
information, any such filings shall be made only in sealed
envelopes on which shall be endorsed the caption of this action
and which shall clearly bear the word "CONFIDENTIAL FILED UNDER
SEAL." All materials filed under seal shall be available to the
Court and to counsel for the parties for viewing and/or copying.
5. The Confidential Schedule and the terms thereof may not be
disclosed to any person not a party to the above-captioned
action, except as expressly provided in paragraph 1 and unless
ordered by a court of competent jurisdiction.
6. This Order shall not prevent any party from applying to the
Court for further or additional protective orders, for the
modification of this Order, or from entering into a written agreement with all other parties to this Order to modify
this Order, subject to approval of the Court.
7. This Order is subject to modification ...