McGuire v. Michigan Department of Community Health et al

Filing 22

STIPULATED PROTECTIVE ORDER Signed by District Judge George Caram Steeh. (MBea)

-MJH McGuire v. Michigan Department of Community Health et al

Doc. 22

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION MATTHEW McGUIRE, Plaintiff, BY ROBERT MCGUIRE, Guardian ad litem, v. STATE OF MICHIGAN DEPARTMENT OF COMMUNITY MENTAL HEALTH, THE MOUNT PLEASANT CENTER, GARY SHEETS, ROOSEVELT ABRAHAM, MICHAEL BORIE, MATTHEW HASSENGER, "DD," "SC," JOHN DOES #1-5, MARK COOPER, PRICE PULLINS, KENNETH T. LONGTON and CYNTHIA KELLY, Defendants. _____________________________________________/ Alyson Oliver (P55020) Jason Dandy (P69686) Attorneys for Plaintiff 24100 Southfield Road, #305 Southfield, Michigan 48075 248.327.6554 James T. Farrell (P35400) C. Adam Purnell (P52634) Assistant Attorneys General Attorneys for Defendants DCH, Mt. Pleasant Center, Sheets, Abraham, Borie, Hassenger, Cooper, Pullins, Longton, & Kelly P.O. Box 30736 Lansing, Michigan 48909 517.373.6434 ______________________________________________/ STIPULATED PROTECTIVE ORDER REGARDING DISCOVERY DOCUMENTS This matter having come before the Court on the stipulation of the parties for a Protective Order, the Court directs that any and all documents produced by Defendants in this litigation, File No. 2:10-cv-10553 HON. GEORGE CARAM STEEH

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either voluntarily or pursuant to Court Order, including but not limited to the following: Department of Community Health operating procedures, policy directives or other rules or regulations; personnel files of state employees, including but not limited to documents defined as personnel records by the Bullard Plawecki Employee Right to Know Act (MCLA 423.501 et seq); training records of the state employees; all investigation materials including police reports, critical incident reports, witness interview statements and all other related materials, medical records, mental health records, prisoner records, photographs, and any other documents produced in the course of litigation, shall be subject to the following conditions: 1. The documents are limited to use in the captioned case of McGuire v State of

Michigan, et al, Case No. 2:10-cv-10553, currently pending in the United States District Court for the Eastern District of Michigan before the Honorable George Caram Steeh. 2. The documents may be reviewed by Plaintiff's counsel and such expert witnesses

as Plaintiff's counsel deems necessary for purposes of this litigation. 3. The documents may also be disclosed to witnesses during deposition proceedings

or trial testimony; however, the witnesses may not leave the deposition with copies of the documents and are bound by the terms of this Protective Order. 4. No person, including Plaintiff's counsel or any expert witness retained by Plaintiff

or Plaintiff's counsel, may retain a copy of the documents; all copies of the documents shall be returned to Defendants' counsel 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 used

by any person for any purpose other than direct use in this litigation.

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6.

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.

IT IS SO ORDERED. Dated: August 2, 2010 s/George Caram Steeh HON. GEORGE CARAM STEEH United States District Judge

Stipulated and Approved for Entry: s/Alyson Oliver w/consent Alyson Oliver (P55020) Jason Dandy (P69686) Attorneys for Plaintiff s/James T. Farrell James T. Farrell (P35400) C. Adam Purnell (P52634) Assistant Attorneys General Attorneys for Defendants DCH, Mt. Pleasant Center, Sheets, Abraham, Borie, Hassenger, Cooper, Pullins, Longton, & Kelly

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