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Kaye v. New York City Health and Hospitals Corp.

United States District Court, S.D. New York

January 8, 2020

MELISSA KAYE, Plaintiff,
v.
NEW YORK CITY HEALTH AND HOSPITALS CORPORATION; ELIZABETH FORD; PATRICIA YANG; ABHISHEK JAIN; and JONATHAN WANGEL (said names being fictitious, the persons intended being those who aided and abetted the unlawful conduct of the named Defendants), Defendants.

          LAW OFFICES OF SPECIAL HAGAN Attorneys for Plaintiff.

          JAMES E. JOHNSON Corporation Counsel of the City of New York Attorneys for Defendants.

          SO-ORDERED STIPULATION AND PROTECTIVE ORDER

         WHEREAS, each party has sought certain documents from the opposing party in discovery in this action, documents which plaintiff or defendants deems confidential; and

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

         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 JS HEREBY STIPULATED AND AGREED, by and between the parties, as follows:

         1. As used herein, "Confidential Materials" shall mean all documents or information concerning current of former employees of the New York City Health and Hospitals Corporation ("H") and the City of New York ("City"), including, but not limited to medical, personnel, disciplinary, time and attendance, payroll, financial, tax records, labor relations, Equal Employment Opportunity ("EEO"), investigative, or other files and the Information contained therein of current or former employees of H and the City.

         2. "Confidential Materials" shall also mean all documents or information in connection to the restructuring of forensic court clinics, the transfer of the forensic court clinics to Correctional Health Services, and any other communications identified by the parties as "Confidential."

         3. Documents and information shall not be deemed "Confidential Materials" to the extent, and only to the extent, that they are (a) obtained by a party from sources other than the party producing the Confidential Materials (the "Producing Party"), or (b) arc otherwise publicly available.

         4. Neither the party receiving the Confidential Materials (the "Receiving Party") nor the Receiving Party's attorneys shall use the Confidential Materials for any purpose other than for the preparation or presentation of the party's case in this action.

         5. Neither the Receiving Party nor the Receiving Party's attorneys shall disclose the Confidential Materials to any person except under the following conditions;

a. Disclosure may be made only if necessary to the preparation or presentation of the party's case in this action.
b. Disclosure before trial may be made to the party, an expert, professional or consultant who has been retained or specially employed by the party's attorneys in anticipation of litigation or preparation for this action, to a witness at deposition or any individual who has been identified as a potential trial witness, or to the Court
c. Before any disclosure is made to a person listed in subparagraph (b) above (other than the Court), Receiving Party shall provide each such person with a copy of this Order, and such person shall consent in writing, in the form annexed hereto as Exhibit "A," not to use the Confidential Materials for any purpose other than in connection with the prosecution of this case and not to further disclose the Confidential Materials except in testimony taken in this case. The signed consent shall be retained by Receiving Party's attorneys and a copy shall be furnished to Producing Party's attorneys upon their request.

         6. Deposition testimony concerning any Confidential Materials which reveals the contents of such materials shall be deemed confidential, and the transcript of such testimony, together with any exhibits referred to therein, shall be separately bound, with a cover page prominently marked "CONHDENTIAL," Such portion of the transcript shall be ...


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