Fletcher v. Michigan Department of Corrections et al

Filing 37

STIPULATED PROTECTIVE ORDER regarding Oakland County Sheriff's Office Policies and Procedures. Signed by District Judge Robert H Cleland. (LWag)

Fletcher v. Michigan Department of Corrections et al

Doc. 37

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION DANIEL FLETCHER, #359391 Plaintiff, v MICHIGAN DEPARTMENT OF CORRECTIONS, OAKLAND COUNTY JAIL, CENTER OF FORENSIC PSYCHIATRY, SHERIFF MICHAEL BOUCHARD, JOHN/SCOTT DOE (1), JOHN DOE (2), JOHN DOE (3), JOHN DOE (4), JOHN DOE (5), JANE DOE, DR. RITA GARG, THOMAS E. FLUENT, M.D., JOSEPH CORSO & BILL CLARK, Defendants. ______________________________________________________________________________/ CRAIG S. ROMANZI & ASSOCIATES, P.C. WILLIAM G. PIERSON (P32119) Oakland County Corporation Counsel HEIDI A. TANNER (P61953) Attorneys for Defendants Oakland County CRAIG S. ROMANZI (P45549) Jail and Sheriff Michael Bouchard Attorneys for Plaintiffs 1200 North Telegraph Road, Bldg. 14 East 2850 Dixie Highway Pontiac, Michigan 48341-0419 Waterford, Michigan 48328 [phone] [phone] ______________________________________________________________________________/ STIPULATED PROTECTIVE ORDER REGARDING OAKLAND COUNTY SHERIFF'S OFFICE POLICIES AND PROCEDURES IT IS HEREBY STIPULATED, by and between the parties hereto, through their undersigned counsel, that Defendant Sheriff Michael Bouchard shall produce Policies and Procedures of the Oakland County Sheriff's Office, as requested by Plaintiff pursuant to this Protective Order that provides: 1. Any Policy and Procedures, Administrative Orders and/or Rules and Regulations (the Documents) of the Oakland County Sheriff's Office produced for inspection and/or copying by Plaintiff shall be used by Plaintiff and his counsel only for the purposes of this litigation and for no other purposes; Case No. 2:09-cv-13904 Hon. Robert H. Cleland Mag. Judge R. Steven Whalen

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The Documents shall not be made public nor available to any person except: a. Such attorneys and supporting staff of Plaintiff that are involved in litigating this action; b. Any expert witness or consultant engaged by Plaintiff to assist in this litigation; Nothing in paragraphs 1 and 2 shall prevent the parties from using the Documents received in discovery in any proceeding in this action including, but not limited to: a. Discovery depositions b. Motions, briefs and pleadings c. Argument before the Court d. Trial or appeal; Counsel shall obtain the written agreement to abide by the terms of this Protective Order by any person being shown the Documents; All Documents produced, including all copies, shall be returned to defense counsel at the conclusion of the litigation. S/Robert H. Cleland Hon. Robert H. Cleland U.S. District Court Judge

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We hereby stipulate to the above order: /s/w consent - Heidi A. Tanner Heidi A. Tanner (P61953) Attorney for Plaintiff 2850 Dixie Highway Waterford, MI 48328 [phone] [e-mail] Dated: July 21, 2010 /s/ William G. Pierson William G. Pierson (P32119) Attorney for Defendant Sheriff Bouchard 1200 N. Telegraph Rd. Pontiac, MI 48341-0419 [phone] [e-mail]

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