He New York City Bar Association Committee Exchange Of Confidential Information Page 4
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15SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ______________________
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:
_______________________________,
:
Index No. ___________
:
Plaintiff,
:
STIPULATION AND ORDER
:
FOR THE PRODUCTION AND
-against-
:
EXCHANGE OF
:
CONFIDENTIAL
_______________________________,
:
INFORMATION
:
Defendant.
:
:
:
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This matter having come before the Court by stipulation of plaintiff, ________________,
and defendant, ___________, for the entry of a protective order pursuant to CPLR 3103(a),
limiting the review, copying, dissemination and filing of confidential and/or proprietary
documents and information to be produced by either party and their respective counsel or by any
non-party in the course of discovery in this matter to the extent set forth below; and the parties,
by, between and among their respective counsel, having stipulated and agreed to the terms set
forth herein, and good cause having been shown;
IT IS hereby ORDERED that:
1.
This Stipulation is being entered into to facilitate the production, exchange and discovery
of documents and information that the parties agree merit confidential treatment
(hereinafter the “Documents” or “Testimony”).
2.
Either party may designate Documents produced, or Testimony given, in connection with
this action as “confidential,” either by notation on the document, statement on the record
of the deposition, written advice to the respective undersigned counsel for the parties
Stipulation and Order for the Production and Exchange of Confidential Information created by
the New York City Bar Association’s Committee on State Courts of Superior Jurisdiction
available at reports/
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