Does et al v. SNYDER et al

Filing 16

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

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
____________________________________________________________________________
JOHN DOES #1 – 4 and MARY DOE,
Plaintiffs,

Case No. 2:12-cv-11194

v.
HON. ROBERT H. CLELAND
RICHARD SNYDER, Governor of the State
of Michigan, and COL. KRISTE
ETUE, Director of the Michigan State
Police, in their official capacities,

MAG. JUDGE DAVID R. GRAND

Defendants.

STIPULATION
The parties hereby Stipulate and Agree:
1.

On April 6, 2012, the Court entered its Order, upon the stipulation of the parties,

extending the time to file Defendants’ response to Plaintiffs’ Motion to Proceed Under Fictitious
Names to April 20, 2012.
2.

On April 18, 2012, the Court entered its Order granting Plaintiffs’ motion.

3.

In light of the fact that the due date for Defendants’ response to Plaintiffs’ motion

had not yet expired when the Court’s Order was entered, counsel for the parties have conferred
and agree that the Court’s April 18, 2012 Order be vacated and that a stipulated Protective Order
be entered in its place.

PROTECTIVE ORDER
In order to protect the interests of the plaintiffs in this action, IT IS ORDERED:
1.

That plaintiffs shall proceed anonymously in this action.

2.

All documents filed with the Court which contain the names of the plaintiffs or

information which identifies the plaintiffs or their family members, directly or indirectly, shall be
filed under seal. In all publicly-filed documents, the plaintiffs shall be identified only by their
pseudonyms.
3.

The plaintiffs’ counsel shall disclose the names of the plaintiffs to counsel for the

defendants by May 1, 2012.
4.

Counsel for the defendants may disclose the identities of the plaintiffs to the

named defendants, employees of the defendants, and experts retained in this case, but only to the
minimum extent necessary to litigate this action.
5.

Individuals to whom disclosure of the plaintiffs’ identities is made shall not

further disclose that information to any other person without first obtaining confirmation from
the defendants’ counsel that such disclosure is necessary to litigate this action.
6.

Any person to whom disclosure is made as a result of this litigation shall first read

this protective order prior to having access to the identities of the plaintiffs. Counsel for the
defendants shall ensure that all persons to whom disclosure is made pursuant to paragraph 3 and
4 are aware of this protective order.
7.

Under no circumstances shall any person disclose the plaintiffs’ names to the

media without the consent of counsel for the plaintiff whose name is to be disclosed.
8.

If any specific issues related to non-disclosure of the plaintiffs’ identities arise

during the course of litigation, the parties shall seek to resolve those issues without court
intervention. If the parties cannot agree, they shall seek further clarification from this court.
SO ORDERED.

Dated: May 1, 2012

s/Robert H Cleland
Hon. Robert H. Cleland
U.S. District Judge

Stipulated and approved for entry:
2

s/Miriam Aukerman (w/consent)___
Miriam Aukerman
American Civil Liberties Union
Fund of Michigan
Attorney for Plaintiffs

s/Margaert A. Nelson (P30342)_________
Margaret A. Nelson
Assistant Attorney General
Attorney for Defendants

3