Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

ID Tech LLC v. Bayam Group, Inc.

United States District Court, S.D. New York

December 20, 2019

ID TECH LLC d/b/a FROST NYC, and NISON KAYKOV, Plaintiff,
v.
BAYAM GROUP, INC. d/b/a BAYAM JEWELRY and TALHA BAYAM, Defendants

          The Law Office Of Alexander Paykin, P.C. Attorneys for Plaintiffs Alexander Paykin, Esq.

          Rothschild & Associates LLC Attorneys for Defendants Attn: Bradley S. Rothschild, Esq.

          STIPULATATION AND ORDER OF CONFIDENTIALITY

          HON. DEBRA FREEMAN UNITED STATES MAGISTRATE JUDGE.

         Plaintiff ID Tech LLC d/b/a Frost NYC and Nison Kaykov, and Defendants Bayam Group, Inc. d/b/a Bayam Jewelry and Talha Bayam have stipulated and agreed to the entry of this Stipulation and Order of Confidentiality ("Order") to protect the discovery and dissemination of confidential and/or proprietary information that may be disclosed in this litigation, and to facilitate the process of discovery relating to such information. Upon a showing of good cause pursuant to Fed.R.Civ.P. 26(c)(1), it is hereby ORDERED that:

         1. All documents, information and other materials designated as Confidential or Highly Confidential and produced or exchanged in the course of this litigation by any party or third-party shall be used or disclosed only in accordance with the terms of this Stipulated Protective Order ("Order").

         2 "Confidential Information," as used herein, means any information of any type, kind, or character that is designated as Confidential by any party or third-party, whether it be a document (in any form), information contained in a document, information revealed during deposition, information revealed in an interrogatory answer, or otherwise. A Party or third-party may designate as Confidential any nonpublic information produced in this litigation which constitutes or contains proprietary or commercially sensitive business or financial information, trade secrets, personal information, private or personal information of any Party's or third-party's customers, or other information approved by the court for inclusion in this order.

         3. "Highly Confidential" Information as used herein includes any document, electronic media, testimony, response to discovery request, transcription of a deposition, or other information designated as Highly Confidential by any Party or third-party. A Party may designate as Highly Confidential any nonpublic information produced in this litigation that constitutes sensitive proprietary and competitive business information that, if disclosed, may impair or destroy the commercial and proprietary value of such information or the privacy rights that attach to it.

         DESIGNATION OF CONFIDENTIAL OR HIGHLY CONFIDENTIAL INFORMATION

         4. Documents, information and other materials produced in this litigation may be designated by any party, or by any third-party producing the documents, information or other materials in this litigation, as Confidential or Highly Confidential by marking each page of the documents so designated with a stamp or label stating that it is "Confidential," or "Highly Confidential - Attorneys' Eyes Only" or otherwise labeling the information or other materials as such at the time of production. Where feasible, any electronic media containing Confidential or Highly Confidential Information shall likewise be marked with a stamp or label stating that it is "Confidential" or "Highly Confidential - Attorneys' Eyes Only."

         5. In designating information as Confidential or Highly Confidential, the party or third- party will make such designation only as to that information which it, in good faith, believes contains Confidential or Highly Confidential Information which is not known or freely obtainable by the general public and which is regarded by that party or third-party as a trade secret, confidential, or proprietary, of or to the disclosing party, including personal information of individuals or insureds, research, any proprietary business information, policyholder and claims-handling information, as well as any development or commercial information. The designations "Confidential Information" and "Highly Confidential Information" shall be used only where necessary to protect information that is of particular sensitivity or value.

         6. The terms Confidential and Highly Confidential do not apply to any documents, information or other materials to the extent that they have been previously disclosed publicly or are otherwise available to the public from any source, provided such prior disclosure or public availability is not the result of wrongful or improper conduct, or in violation of a duty not to disclose. Any party asserting that a document or information is not Confidential or Highly Confidential as a result of circumstances discussed in the preceding sentence must follow the procedures for contesting such a designation set forth in paragraph 21 below. In agreeing that parties and third parties may designate material as Confidential or Highly Confidential the parties do not endorse the propriety of any such designation and reserve all rights to challenge any such designation in accordance with paragraph 21 below.

         7. Information disclosed during a deposition of any party or third-party, or one of its present or former officers, directors, employees, agents or independent experts retained for the purpose of this litigation, may be designated by any party, or by any third-party being deposed, as Confidential or Highly Confidential by indicating on the record at the deposition that the testimony is "Confidential" or "Highly Confidential - Attorneys' Eyes Only" and is subject to the provisions of this Order.

         8. Any party, or any third-party who is being deposed, may also designate information disclosed at such deposition as Confidential or Highly Confidential by notifying all of the parties in writing within thirty (30) days after receipt of the transcript, of the specific pages and lines of the transcript that should be treated as Confidential or Highly Confidential. Each party or third-party shall attach a copy of such written notice or notices to the face of the transcript and each copy thereof in his possession, custody or control.

         9. All deposition transcripts shall be treated as Highly Confidential for a period of thirty (30) days after the receipt of the transcript, except that this provision shall not prevent a deponent from reviewing his or her deposition for purposes of review and signing and/or correcting the transcript. All depositions involving information designated as Confidential or Highly Confidential shall be attended only by the court reporter, the witness, their counsel, and appropriate Qualified Persons as defined below in paragraph 11.

         10. To the extent possible, the court reporter shall mark transcripts as "Confidential" or "Highly Confidential - Attorneys' Eyes Only" when so designated.

         ACCESS TO AND USE OF ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.