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Judge Motley http://nycourts.law.com/CourtDocumentViewer.asp?view=Document&docID=44405 PLAINTIFF LIMITED partnership, with principal place of business in Houston, Texas, owned a crude oil refinery. Defendants were the national oil company of Venezuela and a wholly owned subsidiary. The complaint alleged defendants breached contracts to supply heavy crude oil to plaintiff. Defendants now moved for a protective order barring ex parte contact between plaintiff and certain current and former employees of defendants, on the ground that they were likely exposed to privileged, confidential or business proprietary information or trade secrets. Plaintiff opposed defendants’ motion regarding former non-legal employees of defendants. The court ruled that plaintiff may contact the former employees at issue. It found defendant’s interests sufficiently protected by two stipulations made by plaintiff. First, all interviews would be conducted by attorneys. Second, the questions would be designed to avoid discussion of privileged information.

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