Chamberlain v. Karson et al

Filing 14

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

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
BRANDY CHAMBERLAIN,
Plaintiff,
Case No. 14-11608
vs.
Hon. Robert H. Cleland
MICHAEL KARSON,
Defendants.
__________________________________________________________________/
PAUL W. BROSCHAY (P36267)
PETER W. PEACOCK (P37201)
Law Offices of Paul W. Broschay, PLLC Plunkett Cooney
Attorney for Plaintiff
Attorneys for Defendant
615 Griswold Street, Suite 1712
10 S. Main Street, Ste. 400
Detroit, MI 48226
Mt. Clemens, MI 48043
[phone]
[phone]
[e-mail]
[e-mail]
TODD J. WEGLARZ (P48035)
Law Offices of Todd J. Weglarz, PLLC
Attorney for Plaintiff
615 Griswold Street, Suite 1712
Detroit, MI 48226
[phone]
[e-mail]
__________________________________________________________________/
STIPULATED PROTECTIVE ORDER
At a session of said Court
held in the City of Detroit
County of Wayne, on April 8, 2015
PRESENT: Honorable ROBERT H. CLELAND
United States District Court Judge

The above matter having come before this Court pursuant to the
stipulation of the parties; Plaintiff’s counsel having sought certain documents from
Defendant and Harper Woods and good cause having been shown to the Court being
otherwise informed in the premises, now therefore:
IT IS HEREBY ORDERED AND ADJUDGED that the following
procedures shall govern the production of documents requested by Plaintiff’s counsel:
1.

Defendant will produce the Insurance Policy in effect on

February 19, 2014 for Harper Woods and any of its officers and the Personnel File
of Officer Karson (with personal contact, ssn and date of birth information
redacted). The records produced by Defendant shall be subject to the provisions
of this Protective Order.
2.

Plaintiff and her attorneys shall not reveal such information, nor

show the documents, or reveal the information contained in such documents,
reviewed in and/or provided from the documents to anyone except for the purpose
of discovery and preparation for and the use of all pretrial and trial proceedings of
this cause, including Plaintiff’s expert witness(es). Said information and/or
documents shall be deemed to be confidential and shall be treated as confidential
by anyone who obtains the information or sees the documents.
3.

Said information and/or documents shall be returned to the

Defendant’s counsel at the conclusion of this case and said documents shall not be
copied, published, or in any way disseminated except for use in this case.
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4.

Plaintiff and her attorneys, prior to revealing the information or

showing such documents or revealing the information contained therein to persons
other than employees or agents of the attorneys, shall provide such persons with a
copy of this Protective Order and shall place such persons on notice that such
persons are to return the documents to Plaintiff and her attorneys at the conclusion
of this litigation.
5.

Nothing in this Protective Order shall prevent the parties filing

a Motion for Modification of the Protective Order, either through stipulation, or
good cause shown, and this Court retains continuing jurisdiction to enforce this
Order.

S/Robert H. Cleland
UNITED STATES DISTRICT COURT JUDGE
Approved as to form and content:
/s/Paul W. Broschay___________________
PAUL W. BROSCHAY (P36267)
Attorney for Plaintiff

/s/Peter W. Peacock___________________
PETER W. PEACOCK (P37201)
Attorney for Defendant

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