Jones v. Peco Corporation of Troy

Filing 24

STIPULATED PROTECTIVE ORDER Signed by District Judge Patrick J. Duggan. (MOre)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
PAUL G. JONES, an individual,
Plaintiff,
Case No. 10-cv-13114-JF
Hon. Patrick J. Duggan

v.
PECO CORPORATION OF TROY,
d/b/a PECO CAR WASH SYSTEMS, INC

Defendant.
___________________________________________________________________________/
Brian J. Nagy (P65542)
Attorney for Plaintiff
17000 W. 10 Mile Road, 2nd Floor
Southfield, Michigan 48075
[phone]
[e-mail]

Kay Rivest Butler (P41651)
Trisha M. Benson (P68207)
Starr, Butler, Alexopoulos & Stoner, PLLC
Attorneys for Defendant
20700 Civic Center Drive, Ste. 290
Southfield, MI 48076
[phone]
[e-mail]
[e-mail]

STIPULATED ORDER
PROTECTING CERTAIN INFORMATION
At a session of said Court held in the City of
Detroit, County of Wayne, State of Michigan on:
April 22, 2011/
PRESENT: HON. PATRICK J. DUGGAN
U.S. DISTRICT COURT JUDGE

Upon reading the signed Stipulation of the parties in the above entitled matter, and the
Court being fully advised in the premises;
IT IS HEREBY ORDERED that:
a.
00003092.WPD

Defendant has been requested to produce and during the course of discovery may
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further produce, for inspection and copying, pursuant to Plaintiff’s request, certain personnel and
related records and information regarding its business operations, financial condition, trade secrets
and employees. Such records and information shall be designated "Confidential" by the parties and
subject to the terms of this Protective Order. Either party may challenge the "Confidential"
designation by filing a motion with this Court.
b.

Information obtained pursuant to these requests and documents, and/or copies of the

documents themselves, shall be kept in the custody and care of counsel of record in this action, and
shall be disclosed and used only for the purposes of the conduct of this case and for no other
purpose. Information obtained pursuant to these requests and documents, and/or copies of the
documents themselves, shall be disclosed by Plaintiff's counsel of record only to employees of
Plaintiff’s counsel of record, and/or the named Plaintiff and/or potential witnesses and consultants
only to the extent essential to the preparation of this case and for no other purpose, and provided that
Plaintiff’s counsel shall give all such individuals a copy of this Stipulation and Protective Order and
all such individuals agree to be bound by the terms of this Stipulation and Protective Order.
c.

Individuals having knowledge or information obtained pursuant to these requests and

documents, and/or copies of the documents themselves, by virtue of their participation in the
conduct of this case shall use the information obtained from these requests and documents, and/or
copies of the documents themselves, for that purpose only. Such individuals shall not disclose
information obtained pursuant to these requests and documents, and/or copies of the documents
themselves, to any person or persons not involved in the conduct of this case.
d.

At the conclusion of this matter, all documents designated as"Confidential" produced

by Defendant, including copies thereof, shall be returned to Defendant’s counsel of record.

00003092.WPD

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IT IS SO ORDERED.
s/Patrick J. Duggan
Patrick J. Duggan
United States District Judge
Dated: April 22, 2011
I hereby certify that a copy of the foregoing document was served upon counsel of record on April
22, 2011, by electronic and/or ordinary mail.
s/Marilyn Orem
Case Manager

APPROVED AS TO FORM AND SUBSTANCE:

By:

s/ with consent of Brian J. Nagy
Brian J. Nagy (P65542)
Attorney for Plaintiff
17000 W. 10 Mile Road, 2nd Floor
Southfield, Michigan 48075
[phone]
[e-mail]

By:

s/Kay Rivest Butler
Kay Rivest Butler (P41651)
Starr, Butler, Alexopoulos & Stoner, PLLC
Attorneys for Defendant
20700 Civic Center Drive, Ste. 290
Southfield, MI 48076
[phone]
[e-mail]

00003092.WPD

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