Worley v. AKB Express Inc. et al

Filing 30

STIPULATED PROTECTIVE ORDER pursuant to MCR 2.302(C) Signed by District Judge Robert H. Cleland. (LWag)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
ANNETTE WORLEY,

Gursten, Koltonow, Gursten, Christensen & Raitt, 30101 Northwestern Highway, Farmington Hills MI 48334 [phone]

Plaintiff,
v

Case No. 11-CV-15268
Hon. Robert Cleland

AKB EXPRESS INC., a foreign corporation,
and EMMANUEL G. ADOM,
Defendants.
______________________________________________________________________
__
ROBERT M. RAITT P47017
JOHN T. EADS, III P43815
GURSTEN, KOLTONOW, GURSTEN,
Kopka, Pinkus, Dolin & Eads, P.L.C.
CHRISTENSEN & RAITT, P.C.
Attorneys for Defendants
Attorney for Plaintiff
33533 W. Twelve Mile Rd., Suite 350
30101 Northwestern Highway
Farmington Hills, MI 48331-5611
Farmington Hills, MI 48334
[phone]; Fax [phone]
[phone]; Fax [phone]
[e-mail]
STIPULATED PROTECTIVE ORDER PURSUANT TO MCR 2.302(C)
This matter having come before the Court, and the Court being fully advised in
the premises:
IT IS HEREBY ORDERED that:
1. This Protective Order shall govern the production of the following materials:
a. The name and account number of every banking institution Plaintiff has
had access to since January 2011.
b. Any and all information regarding Plaintiff’s bank accounts maintained
by

Plaintiff’s banking institutions.
c. Any and all information obtained pursuant to authorizations directed at
Plaintiff’s banking institutions.

2. Protected information will be used only for the purposes of litigation and in
compliance with the applicable Michigan Court Rules, including, but not limited to
MCR 2.302(C) and the Michigan Rules of Evidence, and will not be disclosed to

Gursten, Koltonow, Gursten, Christensen & Raitt, 30101 Northwestern Highway, Farmington Hills MI 48334 [phone]

any individual unrelated to this litigation.
3. The provisions of this Stipulated Protective Order shall not terminate at the final
conclusion of this action. Upon termination, either by final judgment after appeal,
if any, or by settlement of this litigation, upon request, Defendant’s counsel shall
return to Plaintiff’s counsel all materials and information protected by this order.
Counsel shall destroy any and all extracts, summaries and analysis of the
information or materials protected by this Order.
4. The attorneys of record are responsible for employing measures to control,
consistent with this Stipulated Protective Order, the duplication of, access to and
distribution of copies of confidential documents. Parties shall not duplicate any
confidential documents except for working copies and/or for filing with the Court
under seal.

DATED: September 27, 2012
s/Robert H. Cleland
UNITED STATES DISTRICT COURT JUDGE

Approved as to form and substance:
/s/ Robert M. Raitt________________
ROBERT M. RAITT P47017
John T. Eads, III _________________
JOHN T. EADS P43825

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Gursten, Koltonow, Gursten, Christensen & Raitt, 30101 Northwestern Highway, Farmington Hills MI 48334 [phone]