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Alvarez v. City of New York

United States District Court, S.D. New York

December 26, 2019

ELBA ALVAREZ, Plaintiff,
v.
THE CITY OF NEW YORK, DENNIS MAZONE, and CHRISTIAN QUINTANILLA, Defendants.

          MAHON, MAHON, KERINS & O'BRIEN, LLC Attorneys for Plaintiff Elba Alvarez Robert O'Brien, Esq.

          JAMES E. JOHNSON Corporation Counsel of the City of New York Attorney for Defendants Christopher Turpin Assistant Corporation Counsel.

          STIPULATION AND PROTECTIVE ORDER

          Hon. Paul Engelmayer, U.S.D.J.

         WHEREAS, plaintiff has sought certain documents and information from defendants in discovery in this action, which defendants deem to be confidential; and

         WHEREAS, defendants object to the production of those documents and information unless appropriate protection for the confidentiality of the information contained therein is assured;

         WHEREAS, an order entered pursuant to Federal Rule of Evidence 502(d) and the Court's inherent Authority will allow the parties in this action to conduct and respond to discovery expeditiously, without fear that disclosure of privileged or protected information will waive such privilege or protection in this or any other proceeding, NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the parties, as follows:

         1. As used herein, "Confidential Materials" shall mean all documents, testimony and information concerning:

a. personnel or former personnel employed by the City of New York in the Office of Chief Medical Examiner ("OCME"), or any of its agencies, including, but not limited to personal information such as home addresses, telephone numbers, social security numbers, and personnel files including all information concerning salary, promotions, discipline and evaluations;
b. Equal Employment Opportunity related materials, but not limited to, complaints, race self-identification information, Equal Employment Opportunity Office files and the information contained in those files;
e. intra- and inter-agency communications and other similar confidential information of the City of New York;
f. taxpayer identification numbers and social security numbers;
g. any information of a personal or intimate nature;
h. any documents that the parties agree are subject to this stipulation;
i. any documents that are designated on the face thereof as ...

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