D'Angelo v. Clinton Township et al

Filing 24

PROTECTIVE ORDER - Signed by Magistrate Judge Mona K Majzoub. (LBar)

UNITED STATED DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THOMAS D’ANGELO,
CASE NO. 2:10-CV-12195
HONORABLE LAWRENCE P. ZATKOFF
MAGISTRATE MONA E. MAJZOUB

Plaintiff,
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]

PROTECTIVE ORDER
The parties hereto having so stipulated, and the Court being otherwise fully advised
in the premises,
IT IS HEREBY ORDERED as follows:
1.

Any document produced by any party to this action (the "Producing Party") for
inspection and/or copying by any other party (the "Discovering Party") that the
producing party reasonably knows is confidential, shall be marked “confidential.”
Any document marked “confidential” shall be used by the Discovering Party only for
the purposes of this litigation and for no other purpose. The Discovering Party shall

not make such “confidential” documents or the information contained therein
available to any person except:
(a)

Such employees of the Discovering Party as are involved in the

prosecuting or defending of this action;
(b)

Attorneys engaged or employed by the Discovering Party and their

supporting staff;
(c)

Any expert witness or consultant engaged by the Discovering Party or

its attorneys to assist in connection with this action.
2.

Nothing in paragraph 1 hereof shall prevent the parties from using documents
marked “confidential” , or the information contained therein, in any proceeding in this
action, including, but not limited to:
(a)
(b)

Motions, briefs and pleadings;

(c)

Argument before the Court;

(d)
3.

Discovery depositions;

Trial or appeal.

Before making any documents marked “confidential,” or the information contained
therein, available to any person described in paragraph 1(c), the Discovering Party
shall obtain from that person a written acknowledgment that he has been given a
copy of this Order, has read it, and agrees to be bound by all of its terms.

4.

At the conclusion of this litigation, all documents marked “confidential,” including
copies, in the possession of the Discovering Party or any other person to whom
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such documents were made available by the Discovering Party, shall be returned
to the Producing Party or destroyed by the Discovering Party, at the option of the
Producing Party. If the Producing Party elects the option of return, the postage for
such return shall be paid by the Producing Party. If the Producing Party elects the
option of destruction, the Discovering Party shall file and serve a sworn certificate
of destruction, attesting to the Discovering Party's full compliance with the
destruction requirement.
5.

Any party may contest the designation of “confidential” for any document, and the
contesting party may bring a motion before the Court concerning the designation.
If such motion is heard, the burden shall be upon the Producing Party to sustain the
designation of “confidential.” The burden for the Producing Party shall be the same
as for any moving party asking for a protective order under Federal Court Rules.

6.

This Order may be modified upon written stipulation of the parties, or by the Court
upon Motion of any party.

Dated: November 17, 2010

s/ Mona K. Majzoub

MONA K. MAJZOUB
UNTIED STATES MAGISTRATE JUDGE

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