Leonor v. Provident Life and Accident Company et al

Filing 27

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

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
LOUIS LEONOR, DDS,
Plaintiff,
v.

Case No. 2:12-cv-15343

PROVIDENT LIFE AND ACCIDENT
COMPANY, a Tennessee Corporation;
and PAUL REVERE LIFE
INSURANCE COMPANY, a
Massachusetts Corporation,

Hon. Robert H. Cleland

Defendants.

Michael M. Jacob (P15391)
Jeffrey D. Wilson (P56376)
Young Basile Hanlon & MacFarlane, PC
3001 W. Big Beaver Road, Suite 624
Troy, MI 48084
[phone] / [phone] Fax
[e-mail]
[e-mail]
Attorneys for Plaintiff

K. Scott Hamilton (P44095)
Dickinson Wright PLLC
500 Woodward Avenue, Suite 4000
Detroit, MI 48226
[phone]
[e-mail]
Attorneys for Defendants

STIPULATED PROTECTIVE ORDER AS TO
DOCUMENTS PRODUCED BY PLAINTIFF AND OTHER DOCUMENTS
At a session of said Court held in the
United States District Court, Eastern District of Michigan,
On December 5, 2013
Present: Honorable Robert H. Cleland
United States District Court Judge

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Defendants having served its First Request for Production of Documents and
Interrogatories dated August 9, 2013, Plaintiff having produced documents in
response to said discovery requests, and the Court being fully advised in the
premises.
IT IS HEREBY ORDERED:
1.

Until further Order of this Court, the foregoing documents produced

by Plaintiff shall be deemed to be CONFIDENTIAL and not be disclosed in any
way, directly or indirectly, in any form, to anyone other than in connection with
this case, and then only to the following persons:
a.
b.

The parties (whether or not dismissed at any time);

c.

Counsel of record in this case and their respective partners,
associates, legal assistants, and staff employees who are
involved in this case;

d.

Independent experts, investigators, consultants, and the like,
retained by any party in connection with this litigation;

e.

2.

The Court and its staff assigned to this case;

Persons deemed by counsel of record, whether or not a party,
witness or deponent, necessary to effectively represent their
respective client(s) in this litigation

Until further Order of this Court, (a) the foregoing documents

produced by Plaintiff, (b) any of the documents previously produced by
Defendants in response to Plaintiff’s First Requests for Admission and for
Production of Documents identified in the Stipulated Protective Order (Dkt # 22)

{YB:00120544.DOCX }

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and (c) any of the documents in Defendants’ files and records, which in any way
relate or refer to Plaintiff’s personal, financial and medical information shall be
marked “CONFIDENTIAL” and filed under seal and in such a manner as not to be
made available in the public record.
3.

Any person who is permitted by counsel to view and/or retain a copy

of any documents covered by this Protective Order shall be provided with a copy
of this Protective Order and shall, by receiving a copy of same and viewing and/or
retaining such documents, agrees to be bound by the terms hereof and shall
acknowledge the same in writing with a copy to opposing counsel.
4.

At any time, either Plaintiff or Defendants may apply to this Court for

an Order excluding specific documents from the protection of this Order.

SO ORDERED

s/Robert H. Cleland
United States District Court Judge

APPROVED AS TO FORM AND SUBSTANCE
NOTICE OF ENTRY WAIVED
Stipulated and agreed to:
By: _/s/ Michael M. Jacob
Michael M. Jacob (P15391)
Attorney for Plaintiff

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_

By: _/s/ K. Scott Hamilton
K. Scott Hamilton (P44095)
Attorney for Defendants

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_