Panzariello v. Botify Inc., Ryan Ambler, Cooper Snowdon, and Maddy McAdams

Summary

This document is a stipulated confidentiality and protective order in Concetta Panzariello v. Botify Inc. et al., pending in the U.S. District Court for the Southern District of New York. It establishes procedures for designating, using, disclosing, challenging, filing, returning, and destroying Confidential and Highly Confidential discovery materials, and includes an undertaking for experts and consultants. The document is dated December 4, 2025.

Holdings

1. The court entered a confidentiality order under Federal Rule of Civil Procedure 26(c)(1) because the litigation may involve trade secrets and confidential research, development, commercial, personal-identifying, and protected-health information whose disclosure could cause harm.
2. Confidential and Highly Confidential information may be used exclusively for purposes of the litigation and may be disclosed only to the persons and under the conditions specified in the order, including required undertakings and notice procedures for experts and consultants.
3. The protective order does not itself authorize filing documents under seal; sealing requires a separate court order supported by an express finding satisfying the applicable sealing requirements.

Questions Presented

1. Whether a protective order should govern confidential and highly confidential information produced in discovery.
2. What restrictions and procedures should govern the designation, disclosure, challenge, filing, and disposition of protected information.

Disposition

other