D'Angelo v. Clinton Township et al

Filing 24

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

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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 (313) 963-5222 (586) 466-7605 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 Page 2 of 3 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 Page 3 of 3 3

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