Martinez v. Finger Management Corp. et al

Filing 60

STIPULATION AND PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material...SO ORDERED. (Signed by Magistrate Judge Katharine H. Parker on 3/26/2024) (vfr)

Revised May 21, 2019

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X
23 CIV 05901 (JPO)(KHP)

Carlos Jose Martinez, individually and on behalf
of all others similarly situated,

Plaintiff(s),

STIPULATION AND
PROTECTIVE ORDER

against
Finger Management Corp. et al.,

Defendant(s).
X

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:
I.

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

3/26/2024