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J.L. v. Beacon City School District

United States District Court, S.D. New York

January 15, 2020

J.L., Plaintiff,
v.
BEACON CITY SCHOOL DISTRICT, et al. Defendants.

          HACH ROSE SCIDRRIPA & CHEVERIE LLP Hillary Nappi Attorneys for Plaintiff

          SILVERMAN & ASSOCIATES Gerald S. Smith Karen C. Rudnicki Attorneys for Defendants

          STIPULATION AND PROTECTIVE ORDER

          KENNETH M. KARAS, JUDGE

         WHEREAS, the Parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for the issuance of an appropriately tailored confidentiality order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby

         ORDERED that the following restrictions and procedures shall apply to the information and documents exchanged by the parties in connection with the pre-trial phase of this action:

         1. Counsel for any party may designate any document or information, in whole or in part, as confidential if counsel determines, in good faith, that such designation is necessary to protect the interests of the client in information that is proprietary, a trade secret or otherwise sensitive non-public information. Information and documents designated by a party as confidential will be stamped "CONFIDENTIAL."

         2. The Confidential Information disclosed will be held and used by the person receiving such information solely for use in connection with the action.

         3. In the event a party challenges another party's designation of confidentiality, counsel shall make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party may 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 reserves the right to object to the use or admissibility of the Confidential Information.

         4. The parties should meet and confer if any production requires a designation of "For Attorneys' or Experts' Eyes Only." All other 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; and
d. The Court (including the mediator, or other person having access to any Confidential Information by virtue of his or ...

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