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Verburg v. Scholastic Inc.

United States District Court, S.D. New York

January 9, 2020

BONNIE VERBURG, Plaintiff,
v.
SCHOLASTIC INC., Defendant.

          OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., Aaron Warshaw Counsel for Defendant.

          MANDEL BHANDARI LLP Rishi Bhandari Counsel for Plaintiff.

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER

          JOHN G. KOELTL, U.S. DISTRICT JUDGE.

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the parties respectfully request that the Court issue a protective order in this action. The parties by and through their undersigned counsel stipulate to the following terms, subject to the Court's approval:

         It is hereby ordered by the Court that the following restrictions and procedures shall apply to certain information, documents and excerpts from documents supplied by the parties to each other in response to discovery requests or otherwise disclosed:

         1. Counsel for any party may designate any document, information contained in a document, information revealed in an interrogatory response or information revealed during a deposition as confidential if counsel determines, in good faith, that such designation is necessary to protect the interests of the client. Information and documents designated by a party as confidential will be stamped "CONFIDENTIAL." "Confidential" information or documents may be referred to collectively as "confidential information."

         2. Unless ordered by the Court, or otherwise provided for herein, the Confidential Information disclosed will be held and used by the person receiving such information solely for use in connection with the above-captioned action.

         3. In the event a party challenges another party's confidential designation, counsel shall make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party may thereafter 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 specifically reserves the right to object to the use or admissibility of all Confidential Information disclosed, in accordance with applicable law and Court rules.

         4. Information or documents designated as "confidential" shall not be disclosed to any person, except:

a. The requesting party and counsel, including in-house counsel;
b. Employees of such counsel assigned to and necessary to assist in the litigation;
c. Consultants or experts assisting in the prosecution or defense of the matter, to the extent deemed necessary by counsel;
d. Any person from whom testimony is taken or is to be taken in these actions, except that such a person may only be shown that Confidential Information during and in preparation for his/her testimony and may not retain the Confidential Information; and
e. The Court (including any clerk, stenographer, or other person having access to any Confidential Information by virtue of his or her position with the Court) court reporters at ...

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