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Ruilova v. 443 Lexington Ave, Inc.
United States District Court, S.D. New York
January 14, 2020
ANDRES RUILOVA, HUGO TEXIS, BERTIN ALDO GARCIA, ISMAEL GUTIERREZ, VALENTIN VIVAR, ELIZABETH KELLY, STACY SAMUEL, STEPHANIE PEREZ, . EVAN MILHO, JAMAL KHAN, KEVIN O'BRIEN and CHUCK REYNOLDS, on behalf of themselves, FLSA Collective Plaintiffs and the Class, Plaintiffs,
443 LEXINGTON AVE, INC. d/b/a DAVIO'S, 75 ARLINGTON STREET, INC, d/b/a DAVIO'S, ONE PATRIOT PLACE, LLC d/b/a DAVIO'S, 151 GRANITE STREET LLC d/b/a DAVIO'S, 55 BOYLSTON STREET, LLC d/b/a DAVIO'S, 427 WALNUT STREET LLC d/b/a DAVIO'S, 111 S. 17TH STREET, INC. d/b/a DAVIO'S, 201 MAIN STREET LLC d/b/a DAVIO'S, and STEVE DIFILLIPPO, Defendants.
Defendants Scott G. Grubin Esq., Mark Berube Esq., Phillip
Plaintiff: C.K. Lee Esq., Angela Kwon Esq., Lee Litigation
Defendants: Robert P. Rudolph Esq., Jonathon D. Freidmann
Esq., Rudolph Freindmann LLP.
J. NATHAN, U.S.D.J.
parties having agreed to the following terms of
confidentiality, and the Court having found that good cause
exists for issuance of an appropriately-tailored
confidentiality order governing the pre-trial phase of this
action, it is therefore hereby
that any person subject to this Order -- Including without
limitation the parties to this action, their representatives,
agents, experts and consultants, all third parties providing
discovery in this action, and all other interested persons
with actual or constructive notice of this Order - shall
adhere to the following terms, upon pain of contempt:
person subject to this Order who receives from any other
person any "Discovery Material" (i.e., information
of any kind provided in the course of discovery in this
action) that is designated as "Confidential"
pursuant to the terms of this Order shall not disclose such
Confidential Discovery Material to anyone else except as
expressly permitted hereunder.
person producing any given Discovery Material may designate
as Confidential only such portion of such material as
(a) previously nondisclosed financial information (including
without limitation profitability reports or estimates,
percentage fees, design fees, royalty rates, minimum
guarantee payments, sales reports and sale margins);
(b) previously nondisclosed material relating to ownership or
control of any nonpublic company;
(c) previously nondisclosed business plans, product
development information, or marketing plans;
(d) any information of a personal or intimate nature
regarding any individual; or (e) any other category of
information hereinafter given confidential status by the
respect to the Confidential portion of any Discovery Material
other than deposition transcripts and exhibits, the producing
person or that person's counsel may designate such
portion as "Confidential" by stamping or otherwise
clearly marking as "Confidential" the protected
portion in a maimer that will not interfere with legibility
or audibility, . With respect to deposition transcripts and
exhibits, a producing person or that person's counsel may
indicate on the record that a question calls for Confidential
information, in which case the transcript of the designated
testimony shall be bound in a separate volume and marked
"Confidential Information Governed by Protective
Order" by the reporter.
at any time prior to the trial of this action, a producing
person realizes that some portion[s] of Discovery Material
that that person previously produced without limitation
should be designated as Confidential, he may so designate by
so apprising all parties in writing, and such designated
portion[s] of the ...