D'Angelo v. Clinton Township et al

Filing 23

STIPULATION AND ORDER settling 7 Motion to Compel - Signed by Magistrate Judge Mona K Majzoub. (LBar) (Main Document 23 replaced on 11/17/2010) (LBar).

UNITED STATED DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THOMAS D=ANGELO,
Plaintiff,

CASE NO. 2:10-CV-12195
HONORABLE LAWRENCE P. ZATKOFF
MAGISTRATE MONA E. MAJZOUB

v.
PAUL PARENT, CLINTON TOWNSHIP,
a municipal entity, NICHOLAS DYKAS,
JASON FIGURSKI and KEITH WATSON,
in their official and individual capacities,
jointly and severally,
Defendants.
_____________________________________________________________________
PETER W. PEACOCK (P37201)
AMOS E. WILLIAMS (P39118)
THOMAS E. KUHN (P37924)
PLUNKETT COONEY
AMOS E. WILLIAMS, P.C.
Attorneys for Defendants Clinton Township
Attorneys for Plaintiff
Dykas, Figurski and Watson
615 Griswold St., Suite 1115
10 S. Main Street, Suite 400
Detroit, Michigan 48226
Mt. Clemens, Michigan 48043
[phone]
[phone]

STIPULATED ORDER REGARDING DISCOVERY
The parties, by and through counsel, hereby agree to the following production of
records pursuant to Plaintiff=s 1st Discovery Request:
Req. 5: Orders and training re. arrests, seizures and questioning of witnesses.
Defendant will produce these orders or policies regarding citizen complaints, use
of force, and seizure/arrest policies subject to a protective order.

Req. 6: Complaints, discipline and internal investigations into arrests, seizures and
questioning.

Defendants object to this request as to relevance but in the interest of discovery
Defendants will produce the requested documents subject to a protective order.

Req. 16: Defendant officer=s personnel files.
Defendants will produce the personnel records subject to a protective order. No
personal information such as home address, telephone numbers, social security
numbers, etc. will be provided.

Req. 12: Complaints and investigations related to complaints lodged against defendant
officers.
Subject to a protective order the Defendants will provide copies of Complaints,
investigations related to complaints lodged against Defendant officers.

Req. 18: Lawsuits alleging violation of 14th and/or 4th Amendments
Lawsuits alleging violation of 14th and/or 4th Amendment claims are available
through public records. However, in the interest of discovery, Defendants will
provide a list of cases, if any, for the subject officers.

Req. 19: Records related to insurance indemnity and assumption of liability
These Defendants object to the production of records related to insurance
indemnity and assumption of liability.

However, in the interest of discovery,

Page 2 of

3

Defendants will provide a copy of the insurance policy subject to a protective
order.
DEFENDANTS

SHALL PROVIDE THE REQUESTED DISCOVERY BEFORE OR ON

NOVEMBER 27,

2010.
IT IS SO ORDERED.
S/ MONA K. MAJOZUB
MONA K. MAJZOUB
UNITED STATES MAGISTRATE JUDGE

OBJECTION TO ENTRY WAIVED:

/S/AMOS E. WILLIAMS
AMOS E. WILLIAMS (P39118)
THOMAS E. KUHN (P37924)
Attorneys for Plaintiff

/S/PETER W. PEACOCK [WITH CONSENT]
PETER W. PEACOCK (P37201)
Attorneys for Defendants Clinton Township
Dykas, Figurski and Watson

Page 3 of

3