This Stipulation re Confidentiality and Protective Order is entered into by Blast Enterprises, Inc., Stephen Brody, and Trudy Brody (collectively, “Plaintiffs”), and Escondido Trafalgar, LLC (“Defendant”), by and through their attorneys of record. In this Agreement, Plaintiffs and Defendants are also referred to individually as a “Party” and collectively as the “Parties.”
IT IS HEREBY STIPULATED by and between the Parties as follows:
1. The documents relating to settlement negotiations between Escondido Trafalgar and tenants or former tenants of Trafalgar Square shopping center produced informally or formally in the captioned litigation (the “Action”), by the Parties or by a third party, may be marked “CONFIDENTIAL – ATTORNEY’S EYES ONLY” …show more content…
Attorney’s Eyes Only Material, and the information contained therein, shall be disclosed only to the counsel for the parties (including paralegal, clerical, and secretarial staff employed by such counsel), but shall not be disclosed to a party, or to an officer, director or employee of a party, unless otherwise agreed or ordered. The Parties shall take all reasonable efforts to keep Attorney’s Eyes Only Material from becoming the public record of the Court.
3. The Parties will not disseminate or make available to any person the Confidential Records other than those specified in paragraph 2 of this Stipulation.
4. If a Party contends that a documents marked as Attorney’s Eyes Only is not of the nature to which such protection should be afforded, the Party making such contention may object to the designation by serving a written objection on all Parties to this action within 60 days after the receipt of the documents identified as Attorney’s Eyes Only. The 60-day period to object may be extended by mutual agreement in writing between the attorneys for the objecting and designating Parties. Thereafter, the objecting Party and the designating Party must make a good faith effort to resolve the objection. If an agreement cannot be reached within 30 days from the date of receipt of the written objection, the objecting Party will have 30 days from the date of receipt of the written objection to move the Court for an order designating the documents as not Attorney’s Eyes Only. If no motion is filed by that time, the Attorney’s Eyes Only designation will remain. If the motion is timely filed, the document must be treated as Attorney’s Eyes Only until the Court rules
IT IS HEREBY STIPULATED by and between the Parties as follows:
1. The documents relating to settlement negotiations between Escondido Trafalgar and tenants or former tenants of Trafalgar Square shopping center produced informally or formally in the captioned litigation (the “Action”), by the Parties or by a third party, may be marked “CONFIDENTIAL – ATTORNEY’S EYES ONLY” …show more content…
Attorney’s Eyes Only Material, and the information contained therein, shall be disclosed only to the counsel for the parties (including paralegal, clerical, and secretarial staff employed by such counsel), but shall not be disclosed to a party, or to an officer, director or employee of a party, unless otherwise agreed or ordered. The Parties shall take all reasonable efforts to keep Attorney’s Eyes Only Material from becoming the public record of the Court.
3. The Parties will not disseminate or make available to any person the Confidential Records other than those specified in paragraph 2 of this Stipulation.
4. If a Party contends that a documents marked as Attorney’s Eyes Only is not of the nature to which such protection should be afforded, the Party making such contention may object to the designation by serving a written objection on all Parties to this action within 60 days after the receipt of the documents identified as Attorney’s Eyes Only. The 60-day period to object may be extended by mutual agreement in writing between the attorneys for the objecting and designating Parties. Thereafter, the objecting Party and the designating Party must make a good faith effort to resolve the objection. If an agreement cannot be reached within 30 days from the date of receipt of the written objection, the objecting Party will have 30 days from the date of receipt of the written objection to move the Court for an order designating the documents as not Attorney’s Eyes Only. If no motion is filed by that time, the Attorney’s Eyes Only designation will remain. If the motion is timely filed, the document must be treated as Attorney’s Eyes Only until the Court rules