Schoolcraft v. The City Of New York et al

Filing 505

LETTER addressed to Judge Robert W. Sweet from Alan H Scheiner dated September 22, 2015 re: Filing of Motion Papers Under Seal Pursuant to Protective Orders. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Kurt Duncan(Shield No. 2483, Individually), William Gough(Tax Id. 919124, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Shantel James(Shield No. 3004 in his official capacity), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Frederick Sawyer(Shield No. 2576 in his official capacity), The City Of New York. (Attachments: # 1 Exhibit Confidentiality Order, # 2 Exhibit Confidentiality Order, # 3 Exhibit Confidentiality Order)(Scheiner, Alan)

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6.

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Deposition testimony concerning any Confidential Materials which

reveals the contents of such materials shall be deemed confidential, and the transcript of such
testimony, together with any exhibits referred to therein, shall be separately bound, with a cover
page prominently marked "CONFIDENTIAL.'' Such portion of the transcript shall be deemed to
be Confidential Materials within the meaning of this Stipulation and Protective Order.
7.

If any paper which incorporates any Confidential Materials or reveals the

contents thereof is filed in this Court, those portions of the papers shall be delivered to the Court
enclosed in a sealed envelope bearing the caption of this action, an indication of the nature of the
contents, and the following legend:

CONFIDENTIAL
This envelope contains documents or information
designated confidential pursuant to an order entered
by the United States District Court for the Southern
District ofNew York in the above-captioned action.
This envelope shall not be opened or unsealed
without the express direction of a judge of this
Court, and its contents shall not be displayed or
revealed except as the Court may order. This
envelope and its contents shall at all times be
maintained separate and apart from the publicly
available files of this case.
8.

Should the City Defendant's produce any Confidentional Materials that

have portions redacted for privilege grounds, such documents or materials shall be accompanied
by a log describing the contents of the redacted portions and the grounds on which the City
Defendants are redacting such portions of the materials so that the parties can properly raise
objections to said redactions with the City Defendants. If such objection cannot be resolved
without the Court's involvement, then any party may move for an order removing such
redactions.

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