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Case 1:23-cv-03903-JSR Document 27 Filed 07/06/23 Page 1 of 12
UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF NEW YORK
IN RE JP MORGAN CHASE & CO. Master Case No. 1:23-CV-03903 (JSR)
DERIVATIVE LITIGATION
DERIVATIVE ACTION
STIPULATION AND [PROPOSED] PROTECTIVE ORDER
The parties having agreed to the following terms of confidentiality, and the Court having
found that good cause exists for issuance of an appropriately tailored confidentiality order
governing the pre-trial phase of this action, it is therefore hereby
ORDERED that any person subject to this Order -- including without limitation the parties
to this action, their representatives, agents, experts and consultants, all third parties providing
discovery in this action, and all other interested persons with actual or constructive notice of this
Order -- shall adhere to the following terms, upon pain of contempt:
1. Any person subject to this Order who receives from any other person any
“Discovery Material” (i.e., information of any kind provided in the course of discovery in this
action) that is designated as “Confidential” pursuant to the terms of this Order shall not disclose
such Confidential Discovery Material to anyone else except as expressly permitted hereunder.
2. The person producing any given Discovery Material may designate as Confidential
only such portion of such material as consists of:
a. previously nondisclosed financial information (including without limitation
profitability reports or estimates, percentage fees, design fees, royalty rates,
minimum guarantee payments, sales reports and sale margins);
Case 1:23-cv-03903-JSR Document 27 Filed 07/06/2
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