State Farm Mutual Automobile Insurance Company v. Hawkins

Filing 101

STIPULATED PROTECTIVE ORDER Signed by District Judge Robert H Cleland. (LWag)

State Farm Mutual Automobile Insurance Company v. Hawkins

Doc. 101

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Case No. 2:08-CV-10367-DT Plaintiff, Honorable Robert H. Cleland v. DEANNA HAWKINS, Defendant. Michael W. Slater (P65227)
HEWSON & VAN HELLEMONT, PC

Thomas W. Cranmer (P25252) David D. O'Brien (P65532)
MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.

Attorneys for Plaintiff 2900 Charlevoix Dr., SE, Ste. 310 Grand Rapids, MI 49546 Tel: [phone]

Attorneys for Third Party Witnesses 840 West Long Lake Rd., Suite 200 Troy, MI 48098-6358 Tel: [phone]

STIPULATED PROTECTIVE ORDER Plaintiff State Farm Mutual Automobile Insurance Company ("State Farm") and third party witness Liss, Seder & Andrews, P.C. (the "Liss Firm"), by and through their respective counsel, hereby stipulate and agree as follows: WHEREAS, on June 9, 2010, the Liss Firm filed a Motion for Protective Order seeking to limit State Farm's use and disclosure of the documents identified in the privilege log that the Liss Firm generated in response to the September 10, 2008 and September 17, 2008 subpoenas served on it by State Farm; and WHEREAS, on June 16, 2010, the Court entered an order granting the Liss Firm's motion and directing it to work with State Farm to stipulate to the form of a protective order; NOW, THEREFORE, the parties stipulate and agree as follows:

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1.

State Farm shall not use any of the documents ordered by this Court to be

produced in connection with the September 10, 2008 and September 17, 2008 subpoenas served on the Liss Firm in this matter, or any information derived from those documents, for any purpose other than the prosecution of its claims in this action. 2. State Farm shall be permitted to disclose the subject documents, and any

information derived from those documents, only to those persons necessary to effectuate the prosecution of its claims in this action. 3. This order is being entered without prejudice to State Farm's ability to file, upon

review of the subject documents, a motion to undue the protection of this order for some or all of the subject documents if used in furtherance of crime or fraud. Stipulated as to form and content by: By: /s Michael W. Slater Michael W. Slater (P65227) Hewson & Van Hellemont PC 2900 Charlevoix Dr. SE, Suite 310 Grand Rapids, MI 49546 Telephone: [phone] [e-mail] Dated: June 17, 2010 By: /s David D. O'Brien David D. O'Brien (P65532) Miller, Canfield, Paddock and Stone, P.L.C. 840 West Long Lake Road, Suite 200 Troy, MI 48098-6358 Telephone: [phone] [e-mail]

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Case No. 2:08-CV-10367-DT Plaintiff, Honorable Robert H. Cleland v. DEANNA HAWKINS, Defendant. Michael W. Slater (P65227)
HEWSON & VAN HELLEMONT, PC

Thomas W. Cranmer (P25252) David D. O'Brien (P65532)
MILLER, CANFIELD, PADDOCK AND STONE, P.L.C.

Attorneys for Plaintiff 2900 Charlevoix Dr., SE, Ste. 310 Grand Rapids, MI 49546 Tel: [phone]

Attorneys for Third Party Witnesses 840 West Long Lake Rd., Suite 200 Troy, MI 48098-6358 Tel: [phone] PROTECTIVE ORDER

Upon review of the above stipulation by Plaintiff State Farm Mutual Automobile Insurance Company ("State Farm") and third party witness Liss, Seder & Andrews, P.C. (the "Liss Firm"), and the Court being fully advised: IT IS HEREBY ORDERED that: 1. State Farm shall not use any of the documents ordered by this Court to be

produced in connection with the September 10, 2008 and September 17, 2008 subpoenas served on the Liss Firm in this matter, or any information derived from those documents, for any purpose other than the prosecution of its claims in this action.

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2.

State Farm shall be permitted to disclose the subject documents, and any

information derived from those documents, only to those persons necessary to effectuate the prosecution of its claims in this action. 3. This order is being entered without prejudice to State Farm's ability to file, upon

review of the subject documents, a motion to undue the protection of this order for some or all of the subject documents if used in furtherance of crime or fraud.

SO ORDERED.

S/Robert H. Cleland ROBERT H. CLELAND UNITED STATES DISTRICT JUDGE Dated: July 7, 2010 I hereby certify that a copy of the foregoing document was mailed to counsel of record on this date, July 7, 2010, by electronic and/or ordinary mail. S/Lisa Wagner Case Manager and Deputy Clerk [phone]

18,082,918.1\144666-00001

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