United States District Court, S.D. New York
MIGUEL RIOS, Individually and on behalf of others similarly situated, Plaintiff,
GASTRO BAR & RESTAURANT CORP. c/o TRYP HOTEL, EROS MANAGEMENT AND REALTY, LLC d/b/a TRYP HOTEL NYC and JOHN SHARMA, Defendants.
SCCHER LAW FIRM, LLP Attorneys for Defendants Austin R.
Klein Law Group P, C. Attorneys for the Plaintiff, Miguel
Rios Darren P.B. Rumack, Esq.
STIPULATION AND ORDER REGARDING CONFIDENTIAL
Kevin Nathaniel Fox, U.S.M.J.
following provisions shall govern the exchange of
confidential information in this matter;
Counsel for any party may designate any document, information
contained in a document, information revealed in an
interrogatory response or information revealed during a
deposition or subpoena response from a third party, as
confidential if counsel determines, in good faith, that such
designation is sensitive commercial data, such as
confidential or proprietary research, development or
commercial or business information, customer lists, financial
data, or employment records of non-parties.. Information and
documents designed as confidential are to be stamped
"CONFIDENTIAL," except the documents disclosed by a
third party may be designated confidential by letter from
counsel. "Confidential" information or documents
may be referred to connectively as "Confidential
Unless ordered by the Court or otherwise provided for herein,
the Confidential Information disclosed will be held and used
by the person receiving such information solely for use in
connection with the above-captioned Action.
the event that a party challenges another party's
designation, counsel shall make a good faith effort to
resolve the dispute, and in the absence of a resolution, the
challenging party may thereafter seek resolution by the
Court, Nothing in this Protective Order constitutes an
admission by any party that Confidential Information
disclosed in this case is relevant or admissible. Each party
specifically reserves the right to object to the use or
admissibility of all Confidential Information disclosed, in
accordance with applicable laws and court rules.
Information or documents designated as
"Confidential" shall not be disclosed to any person
a. The requesting party and counsel, including in-house
b. Employees of such counsel assigned to and necessary to
assist in the litigation; and
c. Any named parties in this action.
d. The Court (including the clerk, court reporter or
stenographer, or other person having access to Confidential
Information by virtue of his or her position with the Court)
or the jury at trial or as exhibits to motions.
e. Subject to the condition set forth in Paragraph 6 below:
consultants or experts in the prosecution or defense of the
matter, to the extent deemed necessary by counsel;
f. Subject to the condition set forth in Paragraph 6 below:
any person from who testimony is taken or is to be taken in
this action, except that such a person may only be shown
Confidential Information during and in preparation for