Sims v. Sony Music Entertainment et al
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Gregory H. Woods on 3/12/2021) (mro)
DATE FILED: 3/12/2021
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-againstSONY MUSIC ENTERTAINMENT, RCA, A
DIVISION OF SONY MUSIC ENTERTAINMENT,
DARRYL CAMPER, JR. D/B/A/ CAMP STAR
MUSIC, JUSTIN ANTHONY BARROSO D/B/A J
LOVE MUSIC, GABRIELLA WILSON A.K.A.
H.E.R., and I AM HER MUSIC,
GREGORY H. WOODS, District Judge:
WHEREAS, the above-captioned Plaintiff, Andre Sims ("Plaintiff') and Defendants
Sony Music Entertainment,' Darhyl Camper, Jr., Gabriella Wilson, HER Music Publishing, Inc.
(incorrectly named as ''I Am Her Music" in the Complaint), and Justin Barroso (collectively,
"Defendants;" together with Plaintiff, the "Parties" and each individually, a "Party") request that
this Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect
the confidentiality of nonpublic and competitively sensitive information that they may need to
disclose in connection with discovery in this action;
WHEREAS, the Parties, through counsel, agree to the following terms; and
WHEREAS, this Court finds that good cause exists for issuance of an appropriately
tailored confidentiality order governing the pretrial phase of this action;
IT IS HEREBY ORDERED that the Parties to this action, their respective officers,
agents, servants, employees, and attorneys, any other person in active concert or participation
with any of the foregoing, and all other persons with actual notice of this Order will adhere to the
following tenns, upon pain of contempt:
Defendant "RCA, A Division of Sony Music Entertainment" is not an independent legal entity
capable of being sued.
March 12, 2021
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