May v. Gallagher et al

Filing 47

STIPULATED PROTECTIVE ORDER Signed by District Judge Robert H. Cleland. (LWag)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
ALAN A. MAY, as Personal Representative
of the Estate of JESUS WINSTON
GILLARD, Deceased,
Plaintiff,
CA: 11-14453
HON: ROBERT H. CLELAND
-vsTOWNSHIP OF BLOOMFIELD, OFFICER JIM
GALLAGHER, OFFICER SEAN KELLEY, OFFICER
SCOTT MONKKONEN, OFFICER JASON MURPHY,
OFFICER JAMES SHOEMAKER, OFFICER APRIL
SWITALA, CITY OF TROY, OFFICER MICHAEL
MEINZINGER, OFFICER SEAN MORSE, OFFICER
CHRISTINA GIOVANNI, AND OFFICER MICHAEL
GIORDANO, Jointly and Severally,
Defendants.
/
FIEGER, FIEGER, KENNEY, GIROUX & DANZIG,P.C.
Geoffrey Nels Fieger (P30441)
Martin T. Shepherd (P65331)
Attorneys for Plaintiff
19390 W. Ten Mile Rd.
Southfield, MI 48075
[phone]
[e-mail]
OAKLAND COUNTY CORP COUNSEL
Lori Grigg Bluhm (P46908)
Julie Quinlan Dufrane (P59000)
Attorneys for Troy Defendants
500 W. Big Beaver Rd.
Troy, MI 48084
[phone]
[e-mail]
[e-mail]

JOHNSON, ROSATI, SCHULTZ & JOPPICH, P.C.
By: Laura S. Amtsbuechler (P36972)
Margaret T. Debler (P43905)
Holly S. Battersby (P72023)
Attorneys for Defendants Bloomfield Twp.,
Gallagher, Kelley, Monkkonen, Murphy,
Shoemaker and Switala
34405 W. 12 Mile Rd., Ste. 200
Farmington Hills, MI 48331-5627
[phone]
[e-mail]
[e-mail]
[e-mail]

/
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") 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 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

received in discovery, or the information contained therein, in any proceeding in this action,
including, but not limited to:
(a) Discovery depositions;
(b) Motions, briefs and pleadings;
(c) Argument before the Court;
(d) Trial or appeal.
3.

Before making any documents produced herein, 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

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read it, and agrees to be bound by all of its terms.
4.

At the conclusion of this litigation, all documents, including copies, produced in

discovery and in the possession of the Discovering Party or any other person to whom 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.

This Order may be modified upon written stipulation of the parties, or by the

Court upon Motion of any party, for good cause shown.
Dated: July 20, 2012
s/Robert H. Cleland
U.S. DISTRICT COURT JUDGE
Stipulated and Agreed to by:
s/ Margaret T. Debler
Laura S. Amtsbuechler (P36972)
Holly S. Battersby (P72023)
Attorneys for Defendants Bloomfield Twp.,
Gallagher, Kelley, Monkkonen, Murphy,
Shoemaker and Switala
34405 W. 12 Mile Rd., Ste. 200
Farmington Hills, MI 48331-5627
[phone]
(P43905)
s/ Martin T. Shepherd (w/consent)
Geoffrey Nels Fieger (P30441)
Martin T. Shepherd (P65331)
Attorneys for Plaintiff
19390 W. Ten Mile Rd.
Southfield, MI 48075
[phone]

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