Stipulation,Agreement: Lg 55 Doe v. Joseph A. Grasso

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                                MONROE COUNTY CLERK’S OFFICE

Return To:
AMY CHRISTINE KELLER

DOE, LG 55

GRASSO, JOSEPH A.

Total Fees Paid: $0.00

State of New York

MONROE COUNTY CLERK’S OFFICE

WARNING — THIS SHEET CONSTITUTES THE CLERKS

ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &

SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.

JAMIE ROMEO.

MONROE COUNTY CLERK

THIS IS NOT A BILL. THIS IS YOUR RECEIPT.

Receipt # 3350068
Book Page CIVIL
No. Pages: 4

Instrument: MISCELLANEOUS DOCUMENT

Control #: 202302280522
Index #: E2020001864

Date: 02/28/2023

Time: 11:33:04 AM

Employee:202302280522 Index #: E2020001864

STATE OF NEW YORK
SUPREME COUNTY COUNTY OF MONROE
LG 55-DOE, :
STIPULATION
Plaintiff,
Index No. E2020001864
v.
JOSEPH A. GRASSO,
Defendant. =

WHEREAS, an Order was signed and entered on June 2, 2020, in connection with
the above action which provides that Plaintiff was permitted to prosecute this action using
the pseudonym “LG 55 Doe” and the Order further provided that the parties were
prohibited from publishing or otherwise disclosing Plaintiff's true name or personal data
or information that would permit a person to ascertain Plaintiffs true name except as
required to prosecute or defend this action; and

WHEREAS, Defendant has filed a motion for summary judgment on the NYSCEF
system which number approximately 500 pages and having also messenger delivered a
complete set of the summary judgment motion papers to the Hon. Charles Schiano, Jr.,
a Monroe County Supreme Court Justice who may be assigned to try the above action
and the motion papers reflect a redacting of Plaintiff's name ‘on the papers in most
instances; and

WHEREAS Plaintiff's counsel requested that eighteen (18) separate documents,
consisting of exhibits and affidavits (hereafler “Removed Documents") be removed from
the NYSCEF filing and that in their place a cover page would be filed identifying the

specific documents contained in the eighteen (18) separate Removed Documents on the

1 bola o® ch : by

15353349.1 1/26/2023 H 4 igrounds that the information in these Removed Documents could permit a third party to
ascertain the identity of the Plaintiff; and

WHEREAS, the parties have agreed to enter into a Stipulation that reflects the

filing of these cover pages in place of the designated Removed Documents.

NOW THEREFORE, the parties agree to the following stipulation:

1. Although the above Removed Documents will be removed from the NYSCEF
filing, the entire summary judgment motion, including these specific Removed
Documents will be provided to the Court in connection with the hearing and
determination of the motion for summary judgment; and

2. It is further stipulated and agreed that in the event there is an appeal from any
decision of this Court, regarding the motion for summary judgment the entire
record on appeal will include the Removed Documents that have been
removed, and said Removed Documents will be provided to the Appetlate

Division in hard copy form only, and not filed electronically on NYSCEF.

af ii hs i i

Dated: Yl , 2023 ae ee
Michael R. Wolford; a

___ Altomeys for the Defendant
* BOND, SCHOENECK & KING, PLLC
350 Linden Oaks
Rochester, NY 14625

15353349.1 1/25/2023Dated: Eb : ¥ , 2023 By:
: ‘Amy Keller, Esq.
\Attorneys for the Plaintiff
@ -LIPSITZ GREEN SCIME CAMBRIA LLP
42 Delaware Avenue, Suite 120
Buffalo, NY 14202-3924

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18353349, 1 1/25/2023