Viacom International, Inc. et al v. Youtube, Inc. et al

Filing 234

STIPULATION AND ORDER: An identical copy of the original forensic images of each of Robert Tur's computers or devices captured by Iris Data Services, LLC, will be provided to a New York office of FTI Consulting, Inc. by the latter of 5pm ET on December 4, 2009 or within 2 business days after the parties submit to the Court a fully executed Stipulation to be so ordered. FTI agrees to execute and be bound by the Protective Order entered in the action. The parties agree to cooperate to use their best efforts to present this stipulation for prompt so-ordering by the Court, including trying to arrange a time with Chambers for presenting and so-ordering same; and notwithstanding the above, if the Court refuses to so order the stipulation, FTI shall immediately return the Forensic Images to Iris. FTI shall do nothing but maintain such Forensic Images in its possession, in strict confidence and in a highly secure location, and shall not review, access, copy, image, investigate, analyze, transfer, or forward the Forensic Images or permit any other person or entity to do so, until either (a) the undersigned counsel of record and special counsel for Mr. Tur have executed a written agreement concerning any constraints posed by any alleged privilege, immunity, confidentiality, privacy, or other protection of the Forensic Images as further set forth in this Order....The provision of the Forensic Images to FTI provided for in paragraph 1 above shall not to any extent waive or prejudice any Protection claimed to be due by or to the Forensic Images or by or to Mr. Tur or any other person or entity. Mr. Tur shall be entitled to designate material or information, or any analyses or results thereof, as Highly confidential under the terms of the Protective Order. (This document was previously sealed in envelope #152 and unsealed on 3/26/2010 by document #199 in 07-cv-3582) (Signed by Judge Louis L. Stanton on 12/14/09) (tro)