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Jordan v. Viacom International, Inc.

United States District Court, S.D. New York

January 9, 2020

KEVIN JORDAN, Plaintiff,
v.
VIACOM INTERNATIONAL INC., Defendant.

          Arlene F. Boop Alterman & Boop LLP Attorneys for Plaintiff

          Laura S. Schnell Eisenberg & Schnell LLP Attorneys for Plaintiff

          Michele A. Coyne, KAUFF MCGUIRE & MARGOLIS LLP Attorneys for Defendant

          CONFIDENTIALITY STIPULATION AND ORDER

          HON. KATHERINE POLK FAILLA, UNITED STATES DISTRICT JUDGE

         WHEREAS, Plaintiff Kevin Jordan and Defendant Viacom International Inc. (together the "Parties" and each a "Party") are engaged in discovery in connection with the captioned action that may involve the production of certain information and deposition testimony which the Parties consider or may consider to be confidential, sensitive, personal, private and/or proprietary, and which should be maintained as confidential in order to protect the legitimate business and privacy interests of the persons who are subject to discovery, their clients and other persons; and

         WHEREAS, the Parties desire to protect against the public or other unauthorized disclosure and the misuse of such information obtained as a result of discovery proceedings in this action.

         NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, on behalf of the Parties, that:

         1. This Confidentiality Stipulation and Order ("Stipulation") shall govern the production and use of all documents, deposition testimony (including all transcription and video-taped recordings of testimony), deposition exhibits, answers to interrogatories and requests for admission, and other written, recorded or graphic discovery materials in the referenced action ("Discovery Material").

         2. This Stipulation is binding upon the Parties, including their respective attorneys, agents, and employees.

         3. Discovery Material specifically designated as Confidential Discovery Material (as defined below), including any portion of the contents thereof, shall be used by the persons receiving such materials and their counsel, subject to the provisions of this Stipulation, solely for the purpose of the prosecution or defense of the claims, defenses, cross-claims and/or counterclaims asserted and filed or amended by the Parties in the litigation, and for no other purpose.

         4. The term "Confidential Discovery Material" shall mean confidential, sensitive, personal, medical, private and/or proprietary commercial, client, business, personnel or financial information, or other information that the disclosure of which would, in the good faith judgment of the Party designating the material as confidential, be an invasion of an individual's privacy or be embarrassing to that Party or be detrimental to the conduct of that Party's business or the personal business of that Party's employees, officers, directors, customers or business contacts. Confidential Discovery Material shall not include information that is or becomes publicly available, other than by a breach by any of the Parties to this Stipulation.

         5. The Party who produces Discovery Material (such individual or entity, a "Producing Party") may designate by written notice any Discovery Material as Confidential Discovery Material under the terms of this Stipulation. The requirement of written notice shall be fulfilled by:

(a) stamping the designated Discovery Material with the legend "Confidential" on each page of such Discovery Material; or
(b) the Producing Party advising, in writing, the recipients of Discovery Material that the Discovery Material produced is Confidential within 10 days of disclosure of the Discovery Material, or within 10 days of the ...

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