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Negotiable Instrument | New York Southern
Stipulation and Order
STIPULATION AND ORDER CONCERNING PROTOCOL FOR PRODUCTION OF DOCUMENTS AND ELECTRONICALLY STORED INFORMATION: Plaintiff Citibank, N.A. ("Citibank"), Plaintiff-Intervenor Luis Barroso Gonzalez ("Barroso"), and Intervenor-Defendant Kauff Laton Miller LLP, solely in its capacity as court-appointed Receiver (the Receiver), by and through the undersigned, HEREBY STIPULATE AND AGREE that this Stipulation and [Proposed] Order Concerning Protocol for Production of Documents and Electronically Stored Information (the "ESI Protocol") shall govern the preservation, collection, processing, review, and production of Documents and ESI in discovery in this Action. The Parties may modify operational details by written agreement if the modification does not alter a Court deadline or other Court order. A substantive modification of this Order, or any modification affecting a Court deadline, requires Court approval. Before seeking modification or other relief, the moving Party shall comply with the meet-and-confer requirements above. (And as further set forth herein.) SO ORDERED. (Signed by Judge Jennifer L. Rochon on 10/1/2026) (jca)
Proposed Stipulation and Order
PROPOSED STIPULATION AND ORDER. Document filed by Luis Barroso Gonzalez..(Ansari, Ramsha)
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