Court records

028_2

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________________x

TEALA DAVIES, Case No. 19 Civ. 10788 (GHW)(DCF)

Plaintiff,

-against-

DARREN K. INDYKE and RICHARD D. KAHN,
as EXECUTORS OF THE ESTATE OF JEFFREY E.
EPSTEIN,

Defendants.
___________________________________________x

STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

WHEREAS, Plaintiff Teala Davies and Defendants Darren K. Indyke and Richard D.

Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (collectively, the “Parties” and each

individually, a “Party”), request that this Court issue a protective order pursuant to Federal Rule

of Civil Procedure 26(c) to protect the confidentiality of nonpublic and sensitive information that

they may need to disclose in connection with discovery in this action;

WHEREAS, the Parties, through counsel, agree to the following terms; and

WHEREAS, this Court finds that good cause exists for issuance of an appropriately

tailored confidentiality order governing the pretrial phase of this action;

IT IS HEREBY ORDERED that the Parties to this action, their respective agents,

employees, and attorneys, any other person in active concert or participation with any of the

foregoing, and all other persons with actual notice of this Order will adhere to the following

terms, upon pain of contempt:
1. With respect to “Discovery Material” (i.e., documents, information or tangible

things of any kind produced or disclosed in the course of discovery in this action) that a person

has designated as “Confidential” pursuant to this Order, no person subject to this Order may

disclose such Confidential Discovery Material to anyone else except as expressly permitted

hereunder.

2. The Party or person producing or disclosing Discovery Material (each,

“Producing Party”)

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