April 16, 2009
OSAMA AHMED FAHMY, PLAINTIFF,
JAY-Z (AKA SHAWN CARTER), TIMOTHY MOSELY, KYAMBO JOSHUA, ROB BOURDON, BRAD DELSON, MIKE SHINODA, DAVE FARRELL, JOSEPH HAHN, CHESTER BENNINGTON, BIG BAD MR. HAHN MUSIC, CHESTERCHAZ PUBLISHING, EMI BLACKWOOD MUSIC, INC., EMI MUSIC PUBLISHING LTD., KENJI KOBAYASHI MUSIC, LIL LULU PUBLISHING, MACHINE SHOP RECORDINGS, LLC, MARCY PROJECTS PRODUCTIONS II, INC., MTV NETWORKS ENTERPRISES INC., NONDISCLOSURE AGREEMENT MUSIC, PARAMOUNT HOME ENTERTAINMENT, INC., PARAMOUNT PICTURES CORPORATION, RADICAL MEDIA, ROB BOURDON MUSIC, ROC-AFELLA RECORDS, LLC, TIMBALAND PRODUCTIONS, INC., UMG RECORDINGS, INC., UNIVERSAL MUSIC AND VIDEO DISTRIBUTION, INC., AND WARNER MUSIC INC., DEFENDANTS.
The opinion of the court was delivered by: The Honorable Patrick J. Walsh
STIPULATION FOR ENTRY OF PROTECTIVE ORDER Discovery Cutoff: July 31, 2009 Pretrial Conf.: August 10, 2009 Trial: TBD
This stipulation is entered into between and among Plaintiff and Defendants (collectively, the "Parties"), through their respective counsel of record.
The Parties stipulate and agree that they have discussed the production of certain documents that the producing Parties contend contain confidential information. The Parties reasonably desire to protect the confidentiality of such information and stipulate and agree that it is appropriate to do so as set forth in the [Proposed] Stipulated Protective Order, attached hereto as Exhibit 1 and concurrently lodged with the Court.
Therefore, the Parties request that the Court enter the [Proposed] Stipulated Protective Order in the form attached hereto as Exhibit 1.
The Honorable Patrick J. Walsh United States Magistrate Judge
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