Cerrito v. Clinton, Charter Township of et al

Filing 16

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

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION PATRICIA S. CERRITO, Plaintiff, Case No. 08-14628 vs. Hon. Robert H. Cleland THE CHARTER TOWNSHIP OF CLINTON, OFFICER JAMES GILCHRIST, Magistrate Judge Virginia M. Morgan

Defendants. _____________________________________________________________________________/ PETER W. PEACOCK (P37201) KEVIN A. CASEY (P41268) Attorney for Defendants CAROL W. GROMBALA (P41597) 10 S. Main Street, Ste. 400 Attorneys for Plaintiff Mt. Clemens, MI 48043 P.O. Box 245 [phone] Romeo, MI 48065 [phone] _____________________________________________________________________________/ STIPULATED PROTECTIVE ORDER At a session of said Court held in the City of Detroit County of Wayne, on September 3, 2009 PRESENT: Honorable Robert H. Cleland United States District Court Judge This matter having come before the Court on the stipulation of the parties for a Protective Order, the Court directs that any policies, procedures and/or training manuals of the Charter Township of Clinton Police Department produced by Defendants in this litigation, either voluntarily or pursuant to Court Order shall be subject to the following conditions: 1. The documents are limited to use in the case of Patricia Cerrito v The

Charter Township of Clinton, et al., Docket No. 08-CV-14628, currently pending in the United States District Court Eastern District of Michigan Southern Division before the Honorable Robert Cleland.

2.

The documents may be reviewed only by counsel of record, counsel of

record's client, counsel of record's support personnel and such expert witnesses and/or consultants as counsel of record deems necessary for purposes of this litigation, as well as any persons to whom the documents may be presented for evaluation and/or evidentiary purposes such as mediators, judge, or jury, subject to the provisions of Paragraphs 3 and 4 below. 3. Any person to whom the documents are shown must be provided with a

copy of this Protective Order and must agree to abide by the terms hereof. 4. No person, including counsel of record, counsel's support personnel

and/or any expert witnesses and/or consultants retained by any party in this matter may retain a copy of the documents; a record of the number of copies made, the name of the person(s) to whom copies have been given and all copies of the documents shall be returned to Defendant's counsel, Peter W. Peacock, upon settlement of this matter or upon entry of a final judgment after all appeals have been exhausted. 5. Neither the actual documents, nor the information contained therein, may

be disclosed to any other person or entity not identified in this Protective Order, nor used by any person for any purpose other than direct use in this litigation. Any documents covered by the Protective Order shall be submitted to the court under seal. 6. The designation by Defendants' counsel of documents subject to the

Protective Order may be challenged by counsel of record pursuant to motion. Documents designated by Defendants' counsel shall remain protected until an order by the court indicates otherwise.

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7.

The violation of any provision of this Protective Order shall be deemed a

contempt of court, and the court may impose appropriate sanctions in the event of violation of this Protective Order.

_s/Robert H. Cleland UNITED STATES DISTRICT COURT JUDGE Approved as to form and content:

_s/Carol W. Grombala__________________ CAROL W. GROMBALA (P41597) Attorney for Plaintiff

s/Peter W. Peacock____________________ PETER W. PEACOCK (P37201) Attorney for Defendants
Branches.01397.84657.1838956-1

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