Opinion
21-CV-01259 (NSR)
08-05-2021
MERCY PEREZ, on behalf of herself and all other persons similarly situated, Plaintiff, v. PEARL RIVER PASTRY, LLC, JOSEPH KOFFMAN and MARTIN KOFFMAN, Defendants.
LAW OFFICE OF PETER A. ROMERO PLLC Peter A. Romero, Esq. David Barnhorn, Esq. Attorneys for Plaintiff. KAUFMAN DOLOWICH & VOLUCK, LLP Keith Gutstein, Esq., Matthew Cohen, Esq. Attorneys for Defendants.
LAW OFFICE OF PETER A. ROMERO PLLC Peter A. Romero, Esq. David Barnhorn, Esq. Attorneys for Plaintiff.
KAUFMAN DOLOWICH & VOLUCK, LLP Keith Gutstein, Esq., Matthew Cohen, Esq. Attorneys for Defendants.
STIPULATION OF CONFIDENTIALITY
HON. NELSON S. ROMAN, J.
IT IS HEREBY STIPULATED AND AGREED, by and between the attorneys for MERCY PEREZ (the “Plaintiff”) and the attorneys for PEARL RIVER PASTRY, LLC, JOSEPH KOFFMAN, and MARTIN KOFFMAN (collectively the “Defendants”) that:
1. All documents produced by the Defendants and/or Defendants' counsel to Plaintiff and/or Plaintiff s counsel, marked “Confidential - For Settlement Purposes Only” (the “Confidential Discovery”) must be kept confidential and cannot be used for any purpose other than for settlement discussions.
2. Plaintiff and Defendants each agree that the Confidential Discovery cannot be used as evidence in any current or future action, or filed with any Court, unless otherwise produced by the Defendants during discovery of such action.
3. Confidential Discovery shall not be disclosed by the receiving party to any person except Plaintiff and Plaintiffs counsel.
4. Upon the conclusion of settlement negotiations and/or upon the request of Defendants' counsel, the Confidential Discovery and any copies thereof shall be promptly returned to the Defendants' counsel or certified as destroyed.
IT IS FURTHER STIPULATED AND AGREED that this Stipulation may be executed in counterparts with scanned PDF or facsimile signatures treated as originals.