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INV Accelerator, LLC v. Vested Interest Co.
United States District Court, S.D. New York
January 6, 2020
INV ACCELERATOR, LLC, Plaintiff,
VESTED INTEREST CO. D/B/A GOLDBEAN, MX TECHNOLOGIES, INC. and JANE BARRATT, Defendants.
ESSES; A W GROUP, LLC Leo L. Esses Attorneys for Plaintiff
INV Accelerator LLC
P.C. Wesley M. Mullen WM1212 Attorneys for Defendants Vested
Interest Co. and Jane Barratt
AARONSON RAPPAPORT FEINSTIN & DEUTSCH LLP Rober J. Cocala
Olga Aleinik Attorneys for Defendant MX Technologies, Inc.
STIPULATION AND PROPOSED PROTECTIVE ORDER
the Parties having agreed to the following terms of
confidentiality, and the Court having found that good cause
exists for the issuance of an appropriately tailored
confidentiality order pursuant to Rule 26(c) of the Federal
Rules of Civil Procedure, it is hereby
that the following restrictions and procedures shall apply to
the information and documents exchanged by the parties in
connection with the pre-trial phase of this action:
1. Counsel for any party may designate any document or
information, in whole or in part, as confidential if counsel
determines, in good faith, that such designation is necessary
to protect the interests of the client in infonnation that is
proprietary, a trade secret or otherwise sensitive non-public
information ("Confidential Information").
Information and documents designated by a party as
confidential will be stamped "CONFIDENTIAL" or
otherwise designated as confidential in writing.
2. The Confidential Information disclosed will be held and
used by the person receiving such information solely for use
in connection with this action.
3. In the event a party challenges another party's
designation of confidentiality, counsel shall make a good
faith effort to resolve the dispute, and in the absence of a
resolution, the challenging party may 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
reserves the right to object to the use or admissibility of
the Confidential Information.
4. The parties should meet and confer if any party contends
that production or disclosure requires a designation of
"For Attorneys' or Experts' Eyes Only," and
in such meet and confer should address both the reasons for
the proposed designations and the limitations on further
disclosure of such documents. All other documents designated
as "CONFIDENTIAL" shall not be disclosed to any
a. The requesting party as necessary to ssists in this action
and counsel, including k-house counsel;
b. Employees of such counsel assigned to and necessary to
assist in this action;
c. Consultants or experts assisting in the prosecution or
defense of this action, to the extent deemed necessary by
d. The Court (including the mediator, or other person having
access to any / Confidential Information
by'virtue of his or her position with the Court); and e.
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