He New York City Bar Association Committee Exchange Of Confidential Information Page 7
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15any necessary secretarial, clerical or other personnel of such officer, if furnished,
shown or disclosed in accordance with paragraph 10 hereof;
f.
trial and deposition witnesses, if furnished, shown or disclosed in accordance with
paragraphs 9 and 10, respectively, hereof; and
g.
any other person agreed to by the parties.
6.
Confidential Information shall be utilized by the Receiving party and its counsel only for
purposes of this litigation and for no other purposes.
7.
Before any disclosure of Confidential Information is made to an expert witness or
consultant pursuant to paragraph 5(c) hereof, counsel for the Receiving party shall
provide the expert’s written agreement, in the form of Exhibit A attached hereto, to
comply with and be bound by its terms. Counsel for the party obtaining the certificate
shall supply a copy to counsel for the other party at the time of the disclosure of the
information required to be disclosed by CPLR 3101(d), except that any certificate signed
by an expert or consultant who is not expected to be called as a witness at trial is not
required to be supplied.
8.
All depositions shall presumptively be treated as Confidential Information and subject to
this Stipulation during the deposition and for a period of fifteen (15) days after a
transcript of said deposition is received by counsel for each of the parties. At or before
the end of such fifteen day period, the deposition shall be classified appropriately.
9.
Should the need arise for any of the parties to disclose Confidential Information during
any hearing or trial before the Court, including through argument or the presentation of
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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