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Confidentiality Agreement

Confidentiality Agreement

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Published by thelocaleastvillage

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Published by: thelocaleastvillage on Aug 21, 2012
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10/23/2012

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UNITED
STATES
DISTRICT
COURTSOUTHERN
DISTRICT
OF
NEW
YORKJOHN
SAWYER PRESTON, BRIAN ORENSTEIN
and JORGE
DEY
ARZA,No.
ll-civ-2556
(WHP)
Plaintiffs,
v.
FT
17
LLC
d/b/a
VELOCE
CLUB,
FT
71b
AVENUE LLC
d/b/a
BAR
VELOCB
CHELSEA, FT
Cafe
LLC
BAR
CARRERA
EAST
VILLAGE,
FT
245
CORP.
d/b/a
BAR
VELOCE EAST VILLAGE,GIULIBTTAMANAGEMENT
CORP.,
FTTCCM
LLC
d/b/a
VELOCE
PIZZERIA,
WEST HOUSTON
MACDOUGALLLCd/bhBARCARRERA
GREENWICH
VILLAGE,and
FREDERICK
TWOMEY,
Defendants.
STIPULATION
AND
PROPOSED ORDER OF CONFIDENTIALITY
IT
IS
HEREBYSTIPULATED
AND
AGREED, by
and
between Plaintiffs
John
Sawyer
Preston, Brian Orenstein
and
Jorge
Deyarza
("Plaintiffs'')
and
Defendants
FT
17
LLC
d/b/a
Veloce
Club,
IT
7
th
Avenue
LLC
d/b/a
Bar Veloce
Chelsea,
IT
Cafe
LLC
Bar Carrera
East
Village,
FT
245 Corp.
d/b/a Bar
Veloce
East Village,
Giulietta
Management Corp.,
FTTCCM LLC
d/b/a
Veloce Pizzeria,
West
Houston MacDougal
LLC
d/b/a Bar Carrera
Greenwich
Village,
and
Frederick
Twomey
("Defendants,"
together
with
Plaintiffs "theParties''),
by
and through their
undersigned counsel,
that:
1.
All
Confidential
Information
produced
by
the
Parties
for
purposes
of
the
Parties' litigation
of
this action
shall
be
subject
to
the
terms and
provisions set forth
herein.
2.
Either
party
may
designate
documents
produced, or testimony
given,
in
connection
with
this action
as
"confidential," either
by
notation
on
the document, statement
on
Case 1:11-cv-02556-WHP Document 32 Filed 08/21/12 Page 1 of 9
 
the
record
of
the deposition,
in
writing
to the
respective counsel for the Parties hereto, or
by
other appropriate means.
3.
The
following tenns, as
used
herein,
shall, without limiting the generality
of
the meaning
of
those tenns,
be
construed as
follows:a) 
The Parties
to
this action shall mean (i) Plaintiffs
and
anyauthorized agent(s), attomey(s) or other entities or person(s) acting
on
their behalf;
and
(ii)
Defendants,
as
well as the employees
and
representatives thereof,
and any
authorized agent( s), attomey(
s)
orother entities or person(s) acting on their behalf.b) "Confidential Information"
means
trade secrets, commerciallysensitive business information,
payroll
documents both thosecreated
in-house
by
any
and/or all Defendants and those created
byan
outside
vendor,
e.g.
Paychex, including but not limited
to:
employee
earnings records, payroll journals, payroll spreadsheets,cash register reports, sales reports,
EDC
transaction reports,
new
hire/re-hire reports, tip sign off reports, invoices, company
and
employee data verification reports, Z reports, cash out sheets,credit card tip sheets, department summaries, shortfall reports, cashrequirements
and
deposit reports, FICA Tip credit reports ortimesheets, employee's personal information including but
not
limited to, social security numbers and contact information,employee
handbooks,
tax
documents, confidentialcommunications, sensitive personal or financial infonnation, that
is
-2
Case 1:11-cv-02556-WHP Document 32 Filed 08/21/12 Page 2 of 9
 
produced
by
the Parties
for the
purpose
of
the
Parties' litigation
of
this
action, except
that
Confidential
Infonnation
shall
not include
(i)
any
information
which
was
lawfully
and
properly in the
possession
of
any
receiving
party
as
of
the
commencement
of
this
lawsuit, or
(ii)
any
infonnation
which
is in the public
domain.4. Any
Confidential
Information produced in
this action shall
be
used
solely
for
the purpose
of
litigating
and
mediating the above-captioned
matter.
5.
Except
as
otherwise provided
in
this Stipulation
of
Confidentiality,
material
designated
as
Confidential
Information
may
be
examined
only
by
the
following persons:
a)
Defendants;
b)
Plaintiffs,
to the
extent
any
Plaintiff is examining his
or
her
own
personneldocuments
or the
payroll records, tip sheets or tipinformation
of
another
Plaintiff.
To
the
extent that a Plaintiff
examinesthe
personnel documents
of
a Plaintiff
other
than
him
or
herself, other than
that Plaintiff's payroll records,
tip
sheets or
tip
infonnation,
he
or she
will
sign
the attached
Agreement
to
beBound
by Stipulation
of
Confidentiality;
c) The
Parties'
respective
counsel
and
employees
of
the
Parties'
counsel
who
are acting
under the
direction
and
control
of
suchcounsel
and
who
are
assisting
such
counsel in this
action;
d) 
To
the extent
necessary for
the prosecution or
defense
of
the
instant
matter,
actual
or proposed witnesses,
independent
consultants
or experts retained in
connection
with the
instant action
-3
Case 1:11-cv-02556-WHP Document 32 Filed 08/21/12 Page 3 of 9

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