diff --git "a/quiet-ml/107/answer2.csv" "b/quiet-ml/107/answer2.csv"
new file mode 100644--- /dev/null
+++ "b/quiet-ml/107/answer2.csv"
@@ -0,0 +1,6974 @@
+doc_id,pdf_orig,pdf_orig_text,pdf_orig_text_ner_type,pdf_orig_text_ner_val
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,ADMINISTRATOR
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,STIPULATION
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,ORDER
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,AL LACV-5600.9RCRNE Defedans
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Feral Rates of Civil
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Federal Rules of Civil
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,ston
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,York City Police Deparment
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ��nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,"medi
+records"
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,NYPD
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Order
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Onler
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Atiomeys for Receiving Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,bas
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,heen reinad
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Exhibit A
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Receiving Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Producing Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,thatthe Receiving Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,The Producing Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Hines
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Contieata
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,thei
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Ma Receiving Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,the Producing Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confidential Materia
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Kt 2 Producing Party’s
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confiental Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,FOIL
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Higation
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Onee
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Receiving Party
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Court
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party��� object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,ZACHARY W. CARTE
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Auorney for Plain Corporation Counsel
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,JOSEPH 212)
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,MCCORMACK
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,MICHAEL LICTTRA
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,ROBERT GALLITELLI
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,VINCENT JOHNSON
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,FRANCISCUS L. DIABA
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Attomey
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Plait
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Suite
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,BARTLETT Atiomey
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Suite
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Mayo Bartlet
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,NEWMAN
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,DIABA Adtomey for Paint
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Pak Ave
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Franciscus L. Diaba
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,BARTLETT
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Pint ‘8
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,White Plains
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,ZACHARY W. CARTER Corporation Counsel
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,JOSEPH MCCORMACK
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,MICHAEL LICITRA
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,ROBERT GALLITELLI
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,VINCENT JOHNSON
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Pant
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Adlai Mba
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,REVINN
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,FOX
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Oumou Bah
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,Mohamed Ba
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",PERSON,CV
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Confidential Materials
+0,Protective_Order.pdf,"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+‘OUMOU BAH, AS THE ADMINISTRATOR
+OP TIEESTATEOF MOHAMED BAK, STIPULATION AND PROTECTIVE. ORDER _ Paint, pine IME CITY OF NEW YORK, ET AL LACV-5600.9RCRNE Defedans
+WITEREAS, the partis hesin intend to produce certin documents pursuant Rule 26 ofthe Feral Rates of Civil Procedure that they dem to be confidential or otherwise inaoproovae for public dislosure: and
+WHEREAS, the pari will only produce these documents sf appropriate rotation for their con detilty is assure: ad
+WHEREAS, good vase exiss forthe entry of an order pursuant to Rule 260) of the Federal Rules of Civil Procedure:
+NOW, THEREFORE, 1 1S HEREBY STIPULATED AND AGREED. by sed besween the altomeys for pantiff and defendants, a5 flows
+1 Asused tern, Acton” shall mean the ove sated ston.
+2 As used herein, “Confidential Materials” shall mean a) Now York City Police Deparment (-NYPD"") personnel secords, b) decedent's nunca records or social security nubers;«) decedent's criminal history, iF any, including but not lined to, arrest,
+indictments, and police reports: 4) decedent's medi
+records; e) medical reconds for Members
+of the Service for treatment relating © the underlying incident; f) records of investigations tepanting the conduct of Members ofthe Service conducted by the NYPD or any other ngeney;
+12) documents that the partes agree are subject this Order; and h) any document thatthe Court directs to he produced subject to this Onler. Such documents and information shail not be deemed “Conteial Material to the extent, and only to the extent, that they ate: (2) obtained
+by plaintiff fom sources other than defendants, or (b) are otherwise publicly available
+‘As used hetein, “Producing Pury” shall mean the pany requesting that a
+particular document or the information contained therein be deemed confidential, and “Receiving
+Party” shall mean any panty who is not the “Producing Party."" as detined herein, for Unat
+document or information.
+4. A Reeeiving Panty and that party's atomeys shall not use Confident
+Materials produced in discovery in the Act
+3 for any purpose other than the cvalustion. preparation, presentation or sttesnent of claims or defenses in the Action,
+5, Atiomeys for Receiving Party shall not disclose the Confidential Materials to any person other than a party, a attorney of record for that party, or any member of the sai ofthat torney's office, except under the following conditions:
+8. Disclosure may be made only if necessary to the preparation oF presentation ofa partys claims or defenses ithe setion,
+b. Disclosure before tial may also be made to an expert of constant who bas heen reinad or specially employed by party's attomey i this ‘action in anticipation of litigation or preparation for this action, to 9 ‘tess at deposition or in preparation for testimony at a depesition or ‘tial o othe Cour,
+Defendants attorneys may also disclose the Confidential Materials to the New York City Police Depertment, the New York City Compleoller's Office, and the Now York City Mayor's Office, solely in connection with the defense a settlement ofthis Action
+4. Before any disiosure is made fo a person listed in subparagraph (©) above (other than to the Court or to a witness at a deposition), the
+Receiving Pary""s altomey shall provide each such person with a copy of this Stipulation and Protective Order, and such person shall consent in weiting, im the form annexed hereto as Exhibit A, not 0 use the Confidential Materials for any purpose other than in connection with the prosecution, defense, or settlement ofthis case and not farther disclose the Confidential Materials, except in testimony taken inthis case. The attorneys for a Receiving Party making such disclosures shall retain the signed consent and furnish a copy to the Producing Party’ atomey vpon request at a deposition oF immediately hefore tial, allhough the name of sn expert thatthe Receiving Party does not intend to call as atrial witness may be redacted from such a consent befor tis produced,
+& Disclosure of medical reords deemed “Confidential” under this Protective Order may also be made t any individual who provided the treatment described in the recorés or to 2 member of the staff of the hospital, doctor's offie, or medical provider where the treatment us seanlered
+6, The Producing Party o¢ its counsel may designate deposition exhibits o¢ postions of deposition transcripts a8 Confidential either by: (4) indicating on the recon during the deposition that a question relates to Confidential Materials, in which event the reporter will
+bind the tenssript ofthe designated testimony in a separate volume and mask it as “Confidential
+Information Govemed by Protective Order” oF (0) notifying the reporter and all counsel of record, in writing, within 30 days after » deposition has concluded, of the specific pages and
+Hines of the transcript tha ate 10 be
+lesignated “Contieata.” in which event all couse! ‘receiving the wanscrip wil be responsible for marking the copies ofthe designated ranserpt in thei posession or under the control as directed by the nding Party or that pays cous
+7. Ma Receiving Party objects to the designtion of any Confidential Materials as confidential, he or she shall state such objection in writing to counsel for the Producing Party and counsel shall in good faith att to resolve such conflict. the confit ‘cnnot be resolved among sonnel, the objecting pany’ shall, within 4S days of the iii
+‘objection, request the Court to remove the designation. Any such materials of information shall
+be rete 2s Confideial uit the paix resolve the confit or the Court issues iis ruling regarding the confit. 8. Any pisty seoking 10 file papers with the Court that ineoporate Confidential Materials or reveal the contents thereo shall ist make an aplication to the Court for permission w flo under sea the spesfic portions of Use papers disclosing Confidential Materia an shal indicate whether any other party’ object to that request. No uteri hal Be Sled oder seal unless the Court has issued an onder approving the filing, in which event the ‘ing sal flow the Dist Cour cules applicable t filing under seal 9."" Nothing this Stipulation and Protective Order shal be consid wo Kt 2 Producing Party’s use of its own Confidential Materials any manner, wt imit the use of Confiental Materials rte contents othe extent tha they are publicly available or have been provided ta party though other lf means, such as a FOIL request. 10, This Prtcetive Order wil survive the temsinaton of the Higation and will
+continue t0 be binding upon all persons to whom Confik
+ial Materials are produced or Aiselossd, All documents or infomation that have been decmed confidential pursuant to this ‘nle, including all copes and non-conforming copies there, shall remain confidential forall time, Onee the Aston has been resolved, including all appeals, the Confidential Materials including al opies nd non-conforming copies thereof, shall not be used bythe Receiving Party
+for any purpose wit
+1 pri Count approval
+Us The Cour will rain jrisdietion overall persons sujet o ths Protective Onde 1o the extent necesary to eaforce say obligtions arising hereunder c¢ fo impose sanetions for ‘ny contempt thereof, Aduittntly, the Court rssrves he right in its sls erin, to modily
+thie Protsctive Onde a ay tie,
+Nothing in this Stipulation and Protective Order shall be construed to Himit the
+producing parties’ use of
+irrespective Confidential Materials in any maint,
+Dated: Februnry 19, 2014 New Yori New York
+NEWMAN FERRARA LLP ZACHARY W. CARTE! Auorney for Plain Corporation Counsel ofthe City of New York 1250 Breadovay, 27"" Floor Auorney for Defendants
+New York, NY 1001 ‘THE CITY OF NEW YORK, JOSEPH 212) 619.5400, MCCORMACK, MICHAEL LICTTRA,
+ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Sree, Room 3-162
+‘New York, New York 10007
+FRANCISCUS L. DIABA, Attomey for Plait 375 Patk Ave, Suite 2607
+New York. New York 10125
+MAYO BARTLETT Atiomey for Paintift
+81 Main Street, Suite 118 ‘White Plains, New York, 10601 (914) 2243086
+By Mayo Bartlet
+2, Nothing ia this Stipulation and Protective Order shall be eonstrued 0 limit the
+producing paties use of their respective Confidential Materials in any manner.
+2m ewe York
+Dated: Fobra. Now York,
+NEWMAN FERRARA LLP invorney for Plain? 1250 Broadway, 27"" Floor News York, NY 10001 212) 610-5400
+fo PRANCISCUS 1. DIABA Adtomey for Paint? 375 Pak Ave Suite 2607 ‘ew York, New York 10125 enyessuvrs
+By Franciscus L. Diaba
+MAYO BARTLETT Attorney for Pint ‘8! Main Street, Suite 118
+White Plains, New York. 1601 (214) 2243080
+By a Staughin
+ZACHARY W. CARTER Corporation Counsel of the City of New York
+THE CITY OF NEW YORK, JOSEPH MCCORMACK. MICHAEL LICITRA, ROBERT GALLITELLI, BRIAN STANTON, ESMERALDA SANTANA and VINCENT JOHNSON
+100 Church Street, Room 3-162
+Now York, New York 10007
+Barry Nyroold’Ashley Gamian
+ABDULWALI MUHA} ‘Astomey for Pant
+81 Main Sect, Suite 118 ‘White Plains. New Yor, 10601 (914) 2243086
+Moe ad By: Abdalicd Much tamed E . Adlai Mba
+soorperen: 2 121114
+REVINN. FOX,
+Bit A
+The undersigned hereby acknowledges that he has read the Stipulation and Provective
+‘Onder eatere! in the United States District Cour for te Southern Distict of Now York dated
+February _ , 2004 iw the action entitled Oumou Bah, as Administrator of the Estate of ‘Mohamed Ba v, The City of New York. eta. 13 CV 604KPKCKKNF) and understands the terms thereof, ‘The undersigned aurees aot to use the Confidential Materials defined therein for any purpose her than in eonnestion with the prosecution of this ease, and will pot further
+disclose the Confidential Materials except in testinony takes inthis ease
+Dae ‘Signatare
+Print Name
+‘Oveupation ",ORG,Dae ‘Signatare