Opinion
21-cv-03217-JGK
05-11-2022
DONALD TURNBULL, Plaintiff, v. JPMORGAN CHASE & CO., Defendant.
MORGAN, LEWIS & BOCKIUS LLP Sarah E. Bouchard (pro hac vice) MORGAN, LEWIS & BOCKIUS LLP Gina F. McGuire Attorneys for Defendant JPMorgan Chase & Co. EMERY CELLI BRINCKERHOFF ABADY WARD & MAAZEL LLP Richard Emery O. Andrew F. Wilson Emma L. Freeman Attorneys for Plaintiff Donald Turnbull
MORGAN, LEWIS & BOCKIUS LLP
Sarah E. Bouchard (pro hac vice)
MORGAN, LEWIS & BOCKIUS LLP
Gina F. McGuire
Attorneys for Defendant JPMorgan Chase & Co.
EMERY CELLI BRINCKERHOFF
ABADY WARD & MAAZEL LLP
Richard Emery
O. Andrew F. Wilson
Emma L. Freeman
Attorneys for Plaintiff Donald Turnbull
STIPULATION AND [PROPOSED] PROTECTIVE ORDER GOVERNING CONFIDENTIALITY OF PRIVILEGED ALLEGATIONS IN THE SECOND AMENDED COMPLAINT
Hon. John G. Koeltl, U.S.D.J
Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, Rule 502 of the Federal Rules of Evidence, and the Court's April 7, 2022 Order (Dkt. 47), Plaintiff Donald Turnbull (“Turnbull”) and Defendant JPMorgan Chase & Co. (“JPMorgan”), by and through their undersigned counsel, hereby stipulate and agree as follows:
1. JPMorgan has designated as “Privileged” the allegations set forth in Paragraphs 67 through 70 of the Second Amended Complaint (the “Privileged Allegations”) regarding the alleged content of JPMorgan's October 7, 2019 interview of Turnbull (the “Privileged Interview”) (jointly, the “Privileged Information”). Redaction and sealing of the Privileged Allegations, as expressly authorized by this Court's Orders dated April 6, 2022 (Dkt. 46) and April 7, 2022 (Dkt. 47), may be made without further application to the Court, and the parties agree that any filings summarizing or otherwise describing the substance of the Privileged Allegations or content of the Privileged Interview shall be filed under seal and otherwise kept confidential.
2. Pursuant to Federal Rule of Evidence 502(d), use or disclosure of Privileged Information in this litigation, whether inadvertent, unauthorized, or otherwise, including, but not limited to, disclosure of (i) the substance of the Privileged Allegations and (ii) the content of JPMorgan's Privileged Interview of Turnbull, shall not be deemed a waiver, in whole or in part, of the privilege or work-product or other applicable immunity, either as to the specific information disclosed or as to the same or related subject matter.
3. Nothing in this Stipulation and Protective Order shall preclude any party from moving the Court to modify this Stipulation and Protective Order to include additional safeguards to protect the confidential and/or privileged nature of other materials.
4. After the conclusion of this action, the provisions of this Stipulation and Protective Order shall continue to be binding until further order of this Court.
SO ORDERED.