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Cuffee v. The City of New York

United States District Court, S.D. New York

January 9, 2020

HIAWATHA CUFFEE, JR., Plaintiff,
v.
THE CITY OF NEW YORK; OFFICER GONZALEZ #17148; and OFFICER SQUILLARO #18036, Defendants.

          JAMES E. JOHNSON Plaintiff Pro Se Corporation Counsel Attorney for Defendants City, Gonzalez, and Squillaro

          Samantha R. Millar Assistant Corporation Counsel

          STIPULATION OF CONFIDENTIALITY AND PROTECTIVE ORDER

          HON. DEBRA C. FREEMAN UNITED STATES MAGISTRATE JUDGE

         WHEREAS, pursuant to Rules 26, 33, and 34 of the Federal Rules of Civil Procedure, Defendants must disclose certain documents and information to Plaintiff in support of their defense pursuant to Plaintiffs discovery demands in this action;

         WHEREAS, Defendants deem those documents and information confidential, private, and/or subject to a law enforcement and/or governmental privileges and/or other applicable privileges;

         WHEREAS, Defendants object to the production of those documents unless appropriate protection for their confidentiality is assured;

         WHEREAS, good cause exists for the entry of an order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure;

         NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and Defendants as follows:

         1. As used herein. "Action" shall mean the pending action between Plaintiff and Defendants captioned Hiawatha Cuffee, Jr. v. City of New York et aly15 CV 8916 (PGG) (DF).

         2. As used herein, without waiving the right to later objections or withholding documents, "Confidential Materials" shall mean:

(A) New York City Department of Correction ("DOC") employment/personnel related records for the individual Defendants;
(B) Any other disciplinary histories or other records, DOC directives and records of investigations regarding the conduct of employees of DOC conducted by DOC, the Inspector General, or other agencies;
(C) DOC training materials;
(D) DOC investigative file relating to underlying incident, including, but not limited to, the Driver's Accident Report for the underlying incident; and (E) Other documents and information that may in good faith, during the pendency of this litigation, be designated ...

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