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In re Aenergy, S.A.

United States District Court, S.D. New York

January 7, 2020

In re Application of Aenergy, S.A. for an Pursuant to 28 U.S.C. § 1782 to Conduct Discovery for Use in a Foreign Proceeding,

          On behalf of Aenergy S.A.: HOLWELL SHUSTER & GOLDBERG LLP SCOTT M. DANNER KEVIN D. BENISH

          On behalf of General Electric Company: COVINGTON & BURLING LLP DAVID Z. PINSKY

          [PROPOSED] STIPULATED PROTECTIVE ORDER

          HON. VALERIE E. CAPRONI UNITED STATES DISTRICT COURT JUDGE.

         Having found that good cause exists, the Court enters, with the consent of the parties to this Proceeding, the following Protective Order under Federal Rule of Civil Procedure 26(c)(1) to facilitate the production of documents and to maintain the confidentiality and limit the use of produced information.

         I. Definitions

         1. “AE” shall mean Aenergy, S.A. and any current or former director, officer, or employee thereof.

         2. “Confidential Information” shall mean all non-public information relating to, referencing, or pertaining to (i) commercially or competitively sensitive information or proprietary information of GE, the disclosure of which would create substantial risk of competitive or business injury to GE or otherwise be disadvantageous to GE's business interests (e.g., marketing documents, business relationships with other parties and other similar information), (ii) personal financial information, (iii) personal identifying information of the type described in Rule 5.2 of the Federal Rules of Civil Procedure, protected by any U.S. or foreign law, or other personally sensitive information, (iv) material that is confidential pursuant to applicable law, including trade secrets, or (v) any other material that the GE believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure.

         3. “Contemplated Action” shall mean the proceeding AE is intending to bring in the courts of the Republic of Angola seeking judicial review of the President of Angola's denial of AE's administrative appeal of a decision by the Angolan Ministry of Power and Water (“MINEA”) to terminate AE's 13 contracts with two public Angolan companies - Empresa Pública de Produção de Electricidade (“PRODEL”) and Empresa Nacional de Distribuição de Electricidade (“ENDE”).

         4. “Discovery Material” shall mean any and all materials, whether physical or electronic, produced or adduced in the course of discovery in this Proceeding, including responses to Subpoenas, deposition testimony and exhibits, and information derived directly therefrom.

         5. “GE” shall mean General Electric Co., and any current or former director, officer, or employee thereof, as well as all its subsidiaries and business units.

         6. “Highly Confidential Information” shall mean highly sensitive Confidential Information that is substantially likely to harm the business interests of GE by the mere disclosure to a party in the Contemplated Action.

         7. “Party” or “Parties” shall mean AE and GE.

         8. "Privileged Matter" shall mean any Discovery Material subject to the attorney-client privilege, work product doctrine, or any other privilege or protection.

         9. “Proceeding” shall mean the above-captioned miscellaneous proceeding.

         10. “Protected Information” shall mean Discovery Material that is designated as Confidential Information or Highly Confidential Information.

         11. “Qualified Person” shall have the meaning ...


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