Opinion
96 Civ. 8414 (KM W)
08-31-2021
Joshua S. Sohn Stroock & Stroock & Lavan LLP Counsel for Plaintiffs William Fraenkel, Office of the Corporation Counsel Counsel for Defendant
Joshua S. Sohn Stroock & Stroock & Lavan LLP Counsel for Plaintiffs
William Fraenkel, Office of the Corporation Counsel Counsel for Defendant
STIPULATION AND PROTECTIVE ORDER
KIMBA M. WOOD, United States District Judge
WHEREAS, plaintiffs and defendant (the “parties”) entered into a Stipulation and Protective Order, which the Court so-ordered on March 31, 2000, as to the treatment of certain “Confidential Materials” produced in this action (the “March 2000 Protective Order”);
IT IS HEREBY STIPULATED AND AGREED, by and between the attorneys for the parties, as follows:
1. The parties agree that the phrase “Confidential Materials, ” as such phrase appears and is defined in the March 2000 Protective Order, shall include any information, in any format, that the parties receive, either directly or via an intermediary, from an “Affected System, ” as that term appears and is defined in the parties' Pension Stipulation and Order, which the Court so-ordered on December 17, 2018 [ECF No. 1014], regardless of the method utilized by the parties to seek such information from an Affected System.
2. This Stipulation and Protective Order shall be deemed effective as of the first date any party received any such Confidential Information in this matter.
SO ORDERED.