The opinion of the court was delivered by: Hon. Paul L. Abrams United States Magistrate Judge
ORDER RE: CONFIDENTIAL DISCOVERY MATERIAL
Date Action Filed: March 18, 2010
Date Action Removed: April 30, 2010
Judge: Hon. Josephine Staton Tucker
Pursuant to the Court's Order Granting Plaintiff's Motion to Compel Further Responses to Plaintiff's First Set of Interrogatories, see Document 26 (filed Aug. 18, 2010), the parties hereby disclose the following:
1. Defendant Loehmann's, Inc. intends to seek review of the foregoing order with the assigned district judge, pursuant to Central District Local Rule 72-2.1.
2. To the extent the foregoing order is not modified or stayed, the parties are in dispute as to whether defendant is entitled to review plaintiff Tiana Daniels's proposed communication to the putative class: Plaintiff intends to send a letter or postcard. Defendant believes it is entitled to review/comment on this communication prior to it being sent out to the putative class. Plaintiff believes defendant is not so entitled.
3. In the interim, as the foregoing order is still in effect, see Local Rule 72-2.2, the parties hereby submit the following Stipulated Protective Order to govern (i) any disclosure and use of putative class members' contact information (with the exception of the disputed review/comment issue, above), and (ii) other confidential documents or information the parties may disclose to each other in the context of this action --
Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and use for any purpose other than prosecuting this litigation would be warranted. This information may specifically include employee payroll data, time-clock data or other employee personnel data, defendant' internal policies, practices or strategies, and employee contact information.To preserve the privacy interests of the putative class members, and of the parties, the parties submit there is good cause for entry of this Protective Order.
Accordingly, IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff Tiana Daniels ("Plaintiff") and Defendant Loehmann's, Inc. ("Loehmann's") (collectively, the "Parties"), through their undersigned counsel, that this Court enter the following Stipulated and Proposed Protective Order Regarding Confidential Discovery Material ("Stipulated Protective Order") with respect to pre-trial discovery. This Stipulated Protective Order will govern documents and information ...