P--R---O--P--O---S-E---D--]- STIPULATED PROTECTIVE ORDERConfidentiality Agreement • May 29th, 2024
Contract Type FiledMay 29th, 2024This Confidentiality Agreement and -[-P--r-o-p--o--s-e-d--]- Stipulated Protective Order (“Order”) is entered into by and among defendants Waste Management, Inc. (“Waste Management” or “WM”), James C. Fish, Jr., Devina A. Rankin, and John J. Morris (“Individual Defendants,” and together with Waste Management, “Defendants”) and lead plaintiffs Seafarers Officers & Employees Pension Plan, Seafarers Money Purchase Pension Plan, and United Industrial Workers Pension Plan (together, “Lead Plaintiffs,” and with Defendants, the “Parties”); and any other persons or entities who may become bound by this Order by signifying their assent through execution of the Declaration attached as Exhibit A to this Order (“Declaration”), for the purpose of expediting production of documents, testimony, and other information (“Production”) in this action (“Action”). The Parties anticipate that documents, testimony, or information containing or reflecting confidential, proprietary, trade secret, and/or commerc