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Lanham v. Lumenis Inc.

United States District Court, S.D. New York

January 2, 2020

MICHELE LANHAM, Plaintiff,
v.
LUMENIS, INC, Defendant.

          Yale Pollack, Esq. Attorneys for Plaintiff

          Carla Varriale, Esq. Attorney for Defendants

          STIPULATION AND ORDER OF CONFIDENTIALITY

          Hon. Alvin K. Hellerstein United States District Judge

         IT IS HEREBY STIPULATED by and between the undersigned counsel for the parties in the above-captioned action as follows pursuant to this Stipulation and Order of Confidentiality (the "Stipulation"):

         1. This Stipulation shall apply to documents marked "Confidential" or "AEO" (meaning for "Attorneys' Eyes Only") by counsel for any party in this action, which shall be referred to herein as the "Confidential Documents."

         2. The Confidential Documents shall be used by the parties and their attorneys solely for the purpose of preparing and conducting this litigation. No. party or person subject to this Stipulation may disclose such information or material to anyone else except as this Stipulation expressly permits.

         3. Neither the Confidential Documents themselves, nor any of the information contained in the Confidential Documents, may be disclosed or used by the parties or their attorneys for any other purpose without further Order of this Court. Neither the Confidential Documents themselves, nor any information contained in the Confidential Documents, may be given, shown, made available or communicated by the parties or their attorneys in any way, either in writing or verbally, to anyone except:

a. The Court (including clerks and other court personnel);
b. Counsel to the parties, including any members of such counsel's law office;
c. The parties, including any employees and board members of such parties, to the extent deemed by counsel disclosing such information to be necessary for the purpose of assisting in the prosecution or defense of this litigation;
d. Court reporters who record deposition or other testimony in the litigation;
e. Experts or consultants retained in connection with the litigation, provided that such experts or consultants are using such information solely in connection with this litigation;
f. Any other person, upon written consent of counsel for the parties.

         4. Any documents marked AEO shall be reviewed by the attorneys only to ...


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