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`FILED: NEW YORK COUNTY CLERK 04372019 10:01 P I
`NYSCEF DOC. NO. 60
`NYSCEF DOC. NO. 60
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`INDEX NO. 650019/2019
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`EXHIBIT B
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`EXHIBIT B
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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
`NYSCEF DOC. NO. 60
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`INDEX NO. 650019/2019
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`Exhibit B
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`FORM OF PROPOSED STIPULATION AND ORDER FOR THE PRODUCTION
`AND EXCHANGE OF CONFIDENTIAL INFORMATION
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY OF NEW YORK:, COMMERCIAL PART 48
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`
`
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`VENTANA EXPLORATION AND
`PRODUCTION LLC,
`
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`Plaintiff(s),
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`
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`- -against -
`-
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`
`
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`Defendant(s).
`JACK RAWDON and DIANA RAWDON,
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`Defendants.
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`
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`Index
`650019/2019
`
`No.:____________.
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`ORDER FOR THE
`PRODUCTION AND
`EXCHANGE OF
`CONFIDENTIAL
`INFORMATION
`Assigned: Masley, J.
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`
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`[PROPOSED] STIPULATION AND ORDER FOR THE
`PRODUCTION AND EXCHANGE OF CONFIDENTIAL INFORMATION
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`This matter having come before the Court by stipulation of plaintiff,
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`____________________ , Ventana Exploration and defendant, _____, (individually
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`“Party” Production LLC (“VEP”), and defendants Jack Rawdon and Diana Rawdon, (collectively
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`“Party” or “Parties”) for the entry of a protective order pursuant to CPLR 3103(a), limiting the
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`review, copying, dissemination and filing of confidential and/or proprietary documents and
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`information to be produced by either pParty and their respective counsel or by any non-party in
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`

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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`the course of discovery in this matter to the extent set forth below; and the pParties, by, between
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`and among their respective counsel, having stipulated and agreed to the terms set forth herein;
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`It is ORDERED that:
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`1.
`This Stipulation is being entered into to facilitate the production, exchange and
`discovery of documents and information that the Parties and, as appropriate, non-parties, agree
`merit confidential treatment (hereinafter the “Documents” or “Testimony”).
`
`2.
`Any Party or, as appropriate, non-party, may designate Documents produced, or
`Testimony given, in connection with this action as “confidential,”Confidential” or “Attorneys’
`Eyes Only” either by notation on each page of the Document so designated, statement on the record
`of the deposition, or written advice to the respective undersigned counsel for the Parties, or by
`other appropriate means.
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`3.
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`Definition of terms used in this stipulation:
`
`(a)
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` “Attorneys’ Eyes Only Information” shall refer to all Documents and
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`Testimony, and all information contained therein, and other information designated as “Attorneys’
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`Eyes Only,” if such Documents or Testimony contain highly sensitive personal or competitive
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`information, the disclosure of which would, in the good faith judgment of the Party or, as
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`appropriate, any non-party designating the material as “Attorneys’ Eyes Only,” be extremely
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`detrimental to the conduct or performance of a Party, that Party’s or non-party’s business or the
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`business of any of that Party’s or non-party’s customers or clients.
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`(a)(b) “Confidential Information” shall mean all Documents and Testimony, and
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`all information contained therein, and other information designated as c“Confidential,” if such
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`Documents or Testimony contain trade secrets, proprietary business information, competitively
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`sensitive information or other information the disclosure of which would, in the good faith
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`2
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`

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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`judgment of the Party or, as appropriate, any non-party designating the material as c“Confidential,”
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`be detrimental to the conduct or performance of that Party’s or non-party’s business or the business
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`of any of that Party’s or non-party’s customers or clients.
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`(b)(c) “Producing Party” shall mean the Parties to this action and any non-parties
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`producing “Confidential Information” or Attorneys’ Eyes Only Information in connection with
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`depositions, document production or otherwise, or the Party or non-party asserting the
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`confidentiality privilege, as the case may be.
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`(c)(d) “Receiving Party” shall mean the Parties to this action and/or any non-
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`partyies receiving “Confidential Information” or Attorneys’ Eyes Only Information in connection
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`with depositions, document production, subpoenas or otherwise.
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`4.
`The Receiving Party may, at any time, notify the Producing Party that the Receiving
`Party does not concur in the designation of a document or other material as Confidential
`Information.or Attorneys’ Eyes Only. If the Producing Party does not agree to classify or
`declassify such document or material within seven (7) days of the written request, the Receiving
`Party may move before the Court for an order classifying or declassifying those documents or
`materials. If no such motion is filed, such documents or materials shall continue to be treated as
`Confidential Information.or Attorneys’ Eyes Only. If such motion is filed, the documents or other
`materials shall be deemed Confidential Informationor Attorneys’ Eyes Only as originally
`designated by the Producing Party, unless and until the Court rules otherwise. Notwithstanding
`anything herein to the contrary, the Producing Party bears the burden of establishing the propriety
`of its designation of documents or information as Confidential Informationor Attorneys’ Eyes
`Only.
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`5.
`Except with the prior written consent of the Producing Party orExcept by Order of
`the Court, Confidential Information shall not be furnished, shown or disclosed to any person or
`entity except to:
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`3
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`(a)
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`personnel of the Parties actually engaged in assisting in the preparation of
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`this action for trial or other proceeding herein and who have been advised of their obligations
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`hereunder;
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`(b)
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`counsel for the Parties to this action and their associated attorneys,
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`paralegals and other professional and non-professional personnel (including support staff and
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`outside copying services) who are directly assisting such counsel in the preparation of this action
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`for trial or other proceeding herein, are under the supervision or control of such counsel, and who
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`have been advised by such counsel of their obligations hereunder;
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`(c)
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`expert witnesses or consultants retained by the Parties or their counsel to
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`furnish technical or expert services in connection with this action or to give testimony with respect
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`to the subject matter of this action at the trial of this action or other proceeding herein; provided,
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`however, that such Confidential Information is furnished, shown or disclosed in accordance with
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`paragraph 79 below;
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`(d)
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`(e)
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`the Court and court personnel;
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`an officer before whom a deposition is taken, including stenographic
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`reporters and any necessary secretarial, clerical or other personnel of such officer;
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`(f)
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`trial and deposition witnesses, if furnished, shown or disclosed in
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`accordance with paragraphs 7-9 and 10, respectively, below; and
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`(g)
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`any other person agreed to by who prepared, received, or reviewed the
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`Producing Party.
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`6.
`Confidential Information shall be utilized by the Receiving Party and prior to its
`counsel only for purposes of production in this litigation and for no other purposes.
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`4
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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`INDEX NO. 650019/2019
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`(a)
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`Before any disclosure of Confidential Information is made to an expert
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`witness or consultant pursuant to paragraph 5 (c) hereof, counsel for the Receiving Party making
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`such disclosure shall provide to the expert witness or consultant a copy of this Stipulation and
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`request the expert’s or consultant’s written agreement, in the form of Exhibit 1 attached, to comply
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`with and be bound by its terms. Counsel for the Receiving Party obtaining the certificate shall
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`supply a copy to counsel for the other Parties at the time designated for expert disclosure, except
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`that any certificate signed by an expert or consultant who is not expected to be called as a witness
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`at trial is not required to be supplied.
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`(g)
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`action provided it appears on the face of the document or from other
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`evidence that the person prepared, received, or reviewed the Confidential Information; and
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`(h)
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`any other person provided that all Parties have provided written consent for
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`such person to review the Confidential Information.
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`6.
`Except by Order of the Court, “Attorneys’ Eyes Only Information” may be
`disclosed only to:
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`(a)
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` a Party’s experts and consultants, as defined in Paragraph 5(c), which
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`have agreed to be bound by the terms of this Stipulation as set forth in Paragraph 10; and
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`(b)
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`a Party’s outside counsel.
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`7.
`All depositions shall presumptively be treated as Confidential Information and
`subject to this Stipulation during the deposition and for a period of fifteen (15) days after a
`transcript of said deposition is received by counsel for each of the Parties. At or before the end of
`such fifteen-day period, the deposition shall be classified appropriately.
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`8.
`Should the need arise for any Party or, as appropriate, non-party, to disclose
`materials designated as Confidential Informationor Attorneys’ Eyes Only during any hearing or
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`5
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`trial before the Court, including through argument or the presentation of evidence, that Party or,
`as appropriate, non-party may do so only after taking such steps, if any, that the Court, following
`a motion by the Producing Party, shall deem necessary to preserve the confidentiality of such
`Confidential Information. or Attorneys’ Eyes Only Information.
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`9.
`This Stipulation shall not preclude counsel for any Party from using during any
`deposition in this action any Documents or Testimony which hasve been designated as
`“Confidential Information” under the terms hereof. If a Party seeks to give access to Confidential
`Information to a deposition witness who is not otherwise permitted to view the Confidential
`Information under the terms of this Stipulation, the Party shall provide the witness with a copy of
`this Stipulation and request that the witness execute a written agreement, in the form of Exhibit 1
`attached below, to comply with and be bound by its terms. Counsel for the Party obtaining the
`certificateexecuted agreement shall supply a copy to counsel for the other Parties and, as
`appropriate, aany non-party that is a Producing Party. In the event that a witness refuses to execute
`the agreement to be bound by this Stipulation, the Court may, upon application, enter an order
`directing the witness’s compliance with the Stipulation, or directing such other steps as the Court
`may deem necessary under the circumstances.
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`10.
`All persons to whom Confidential Information is disclosed, except those identified
`in Paragraphs 5(a)-(b) and (d), above, shall execute an agreement in the form annexed hereto as
`Exhibit 1, and shall agree to be bound by this Stipulation, before receiving Confidential or
`Attorneys’ Eyes Only Information. Counsel for each Party shall maintain the executed agreements
`and need not provide copies to any other Party unless there is a genuine dispute between the Parties
`concerning the person’s handling of Confidential Information, or except as expressly provided for
`herein.
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`10.11. A Party may designate as “Confidential Information” or “Attorneys’ Eyes Only”
`subject to this Stipulation any document, information, or deposition testimony produced or given
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`6
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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`by any non-party to this case, or any portion of such materials or information. In the case of
`Documents, produced by a non-party, designation shall be made by notifying all counsel in writing
`of those documents which are to be stamped and treated as such at any time up to fifteen (15) days
`after actual receipt of copies of those documents by counsel for the Party asserting the
`confidentiality privilege. In the case of deposition Testimony, designation shall be made by
`notifying all counsel in writing of those portions which are to be stamped or otherwise treated as
`such at any time up to fifteen (15) days after the transcript is received by counsel for the Party (or,
`as appropriate, non-party) asserting the confidentiality. Prior to the expiration of such fifteen (15)
`day period (or until a designation is made by counsel, if such a designation is made in a shorter
`period of time), all such Documents and Testimony shall be treated as Confidential Information.
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`11.12. (a) A Receiving Party who seeks to file a motion with the Court using Documents
`or Testimony which have previously been designated as comprising or containing Confidential or
`Attorneys’ Eyes Only Information, and/or any pleading, brief, or memorandum, which reproduces,
`paraphrases, or discloses Confidential or Attorneys’ Eyes Only Information, shall, fourteen (14)
`days prior to filing any motion, provide the Parties with written notice of its intent to file such
`material with the Court, so that the Producing Party may file, by Order to Show Cause, a motion
`to seal or redact such Confidential Informationinformation in conformance with the Part 48
`Practice Rules and other applicable rules and procedures. A Party seeking to file a motion with the
`Court using any Documents or Testimony that it has designated as confidential must also move to
`seal or redact such Confidential or Attorneys’ Eyes Only Information. The motion to seal or redact
`the Confidential Informationinformation must be filed seven (7) days prior to filing the motion,
`and the Confidential and/or Attorneys’ Eyes Only Information shall be filed under temporary seal
`until the Court renders a decision on the motion to seal or redact the document(s).
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`(b)
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`If the motion to seal or redact is granted, the filing party shall ensure that all
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`documents that are the subject of the order to seal or redact are filed in accordance with the
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`7
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`

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`procedures that govern the filing of sealed or redacted documents on the NYSCEF system and in
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`conformance with the Part 48 Practice Rules.
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`(c)
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`All pleadings, briefs or memoranda which reproduces, paraphrases or
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`disclosesreproduce, paraphrase or disclose any documents which have previously been designated
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`by a party as comprising or containing Confidential or Attorneys’ Eyes Only Information shall
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`identify such documents by the production number ascribed to them at the time of production.
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`13.
`Confidential or Attorneys’ Eyes Only Information shall be utilized by the
`Receiving Party and its counsel only for purposes of this litigation and for no other purposes.
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`12.14. Any person receiving Confidential or Attorneys’ Eyes Only Information shall not
`reveal or discuss such information to or with any person not entitled to receive such information
`under the terms of this Stipulation and shall use reasonable measures to store and maintain the
`Confidential and/or Attorneys’ Eyes Only Information so as to prevent unauthorized disclosure.
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`13.15. Any document or information that may contain Confidential or Attorneys’ Eyes
`Only Information that has been inadvertently produced without identification as to its
`“confidentialConfidential” or “Attorneys’ Eyes Only” nature as provided in paragraphs 2 and/or
`11 of this Stipulation may be so designated by the party asserting the confidentiality privilege by
`written notice to the undersigned counsel for the Receiving Party identifying the document or
`information as “confidentialConfidential” or “Attorneys’ Eyes Only” within a reasonable time
`following the production from which the document or information was disclosed without such
`designation.
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`14.16. Extracts and summaries of Confidential or Attorneys’ Eyes Only Information shall
`also be treated as confidential in accordance with the provisions of this Stipulation.
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`15.17. The production or disclosure of Confidential or Attorneys’ Eyes Only Information
`shall in no way constitute a waiver of each Producing Party’s right to object to the production or
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`8
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`

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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`disclosure of other information in this action or in any other action. Nothing in this Stipulation
`shall operate as an admission by any Party or non-party that any particular document or
`information is, or is not, confidential. Failure to challenge a Confidential Informationor Attorneys’
`Eyes Only designation shall not preclude a Party or non-party from making a subsequent challenge
`as to those dDocuments or information.
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`16.18. This Stipulation is entered without prejudice to the right of any Party or non-party
`to seek relief from, or modification of, this Stipulation or any of its provisions by properly- noticed
`motion to the Court, or to challenge any designation of confidentiality as inappropriate under the
`Civil Practice Law and Rules or other applicable law.
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`17.19. This Stipulation shall continue to be binding after the conclusion of this litigation;
`however, there shall be no restriction on documents that are used as exhibits in Court unless, and
`only insofar as, such exhibits were sealed or redacted pursuant to an order of the Court).. Further,
`nothing in this Stipulation prevents a Receiving Party from seeking the written permission of the
`Producing Party, or further order of the Court, to dissolve or modify the Stipulation. The provisions
`of this Stipulation shall, absent prior written consent of the parties, continue to be binding after the
`conclusion of this action; however, documents sealed or redacted by order of the Court prior to, or
`for a purpose other than, trial shall not remain sealed or redacted for use as trial exhibits absent
`further order of the Court extending the sealed or redacted status of such documents for use at trial.
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`18.20. Nothing in this Stipulation shall be deemed to waive any privilege recognized by
`law, or shall be deemed an admission as to the admissibility in evidence of any facts or documents
`revealed in the course of disclosure.
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`19.21. Within sixty (60) days after the final termination of this litigation by settlement or
`exhaustion of all appeals, all Confidential and Attorneys’ Eyes Only Information produced or
`designated, and all reproductions of such materials, shall be returned to the Producing Party or, at
`the Receiving Party’s option, shall be destroyed.; however, any documents or information that
`
`
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`9
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`

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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`INDEX NO. 650019/2019
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`constitute “VEP materials,” as defined in the April 29, 2019 Stipulation and Proposed Order
`regarding Plaintiff’s February 8, 2019 Motion for a Preliminary Injunction, shall be destroyed at
`Plaintiff’s request. In the event that any Receiving Party chooses to destroy physical objects and
`documents, that Receiving Party shall certify in writing within sixty (60) days of the final
`termination of this litigation that it has undertaken its best efforts to destroy such physical objects
`and documents, and that such physical objects and documents have been destroyed to the best of
`its knowledge. Notwithstanding anything to the contrary, counsel of record for the Parties may
`retain one copy of documents constituting work product, a copy of pleadings, motion papers,
`discovery responses, deposition transcripts, and deposition and trial exhibits. This Stipulation shall
`not be interpreted in a manner that would violate any applicable rules of professional conduct.
`Nothing in this Stipulation shall prohibit or interfere with the ability of counsel for any Receiving
`Party, or of experts specially retained for this case, to represent any individual, corporation or other
`entity adverse to any Party or non-party or their affiliate(s) in connection with any other matter.
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`20.22. If a Receiving Party is called upon to produce Confidential or Attorneys’ Eyes Only
`Information in order to comply with a court order, subpoena, or other direction by a court,
`administrative agency, or legislative body, the Receiving Party from which the Confidential and/or
`Attorneys’ Eyes Only Information is sought shall (a) give written notice by overnight mail and
`either email or facsimile to the counsel for the Producing Party within five (5) business days of
`receipt of such order, subpoena, or direction, and (b) give the Producing Party five (5) business
`days to object to the production of such Confidential Informationinformation, if the Producing
`Party so desires. Notwithstanding the foregoing, nothing in this paragraph shall be construed as
`requiring any party to this Stipulation to subject itself to any penalties for noncompliance with any
`court order, subpoena, or other direction by a court, administrative agency, or legislative body.
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`21.23. This Stipulation may be changed by further order of this Court, and is without
`prejudice to the rights of a Party to move for relief from any of its provisions, or to seek or agree
`to different or additional protection for any particular material or information.
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`
`
`10
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`22.24. This Stipulation may be signed in counterparts, which, when fully executed, shall
`constitute a single original, and electronic signatures shall be deemed original signatures.
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`By:
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`Deleted Cells
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`Deleted Cells
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`CounselBy: /s/ Joseph Dever
`COZEN O’CONNOR
`
`Joseph Dever
`William Lesser
`45 Broadway, 16th Floor
`New York, New York 10006
`Telephone: (212) 509-9400
`
`Attorneys for Defendant(s)Defendants Jack Rawdon
`and Diana Rawdon
`
`By:
`Dated: New York, New York
` April 29, 2019
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`(212) 446-
`
`CounselBy: /s/ Jeffrey L.
`
`Willian
` KIRKLAND & ELLIS
`LLP
`Jeffrey L. Willian, P.C.
`Kyla Jackson
`601 Lexington Avenue
`New York, New York
`10022
`Telephone: (212) 446-
`4800
`Facsimile:
`4900
`
`Donna M. Welch, P.C.
`Benjamin T. Kurtz
`300 North LaSalle
`Chicago, Illinois 60654
`Telephone: (312) 862-
`2000
`Facsimile: (312) 862-
`2200
`
`Attorneys for Plaintiff(s)
`Ventana
`Exploration and
`Production LLC
`
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`
`11
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`Dated: _________________
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`Dated: ___________________, 2019
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`SO ORDERED:
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`
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`SO ORDERED:
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`
`
`
`
` .
`Masley, J.S.C.
`
`
`
`12
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`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`Exhibit 1
`
`SUPREME COURT OF THE STATE OF NEW YORK
`
`COUNTY OF NEW YORK: COMMERCIAL PART 48
`
`
`
`
`VENTANA EXPLORATION AND
`PRODUCTION LLC,
`
`
`Plaintiff(s),
`
`
`
`- -against -
`-
`
`
`
`
`Defendant(s).
`JACK RAWDON and DIANA RAWDON,
`
`Defendants.
`
`
`
`
`
`
`
`
`
`
`
`
`Index
`650019/2019
`
`No.:____________.
`
`Assigned: Masley, J.
`
`IAS Part 48
`
`AGREEMENT WITH
`RESPECT TO
`CONFIDENTIAL
`MATERIAL
`
`
`
`
`I, ________________________________________________, state that:
`
`1. My address is _____________________________________________________________ .
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`2. My present occupation or job description is ______________________________________ .
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`3. I have received a copy of the Stipulation for the Production and Exchange of Confidential
`Information (the “Stipulation”) entered in the above-entitled action on ____________, 2019.
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`4. I have carefully read and understand the provisions of the Stipulation.
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`5. I will comply with all of the provisions of the Stipulation.
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`6. I will hold in confidence, will not disclose to anyone not qualified under the Stipulation, and
`will use only for purposes of this action, any Confidential Information that is disclosed to me.
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`7. I will return all Confidential Information that comes into my possession, and documents or
`things that I have prepared relating thereto, to counsel for the party by whom I am employed
`or retained, or to counsel from whom I received the Confidential Information.
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`8. I hereby submit to the jurisdiction of this court for the purpose of enforcement of the
`Stipulation in this action.
`
`
`
`

`

`FILED: NEW YORK COUNTY CLERK 04/29/2019 10:01 PM
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`Dated: ________________________
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`Signature: ___________________________
`
`
`
`
`
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`14
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