Carter v. Redford Township et al

Filing 19

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

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
DeJUAN CARTER,
Plaintiff,
v.

CASE NO: 2:15-cv 11370
HON: ROBERT H. CLELAND
MAG. MONA K. MAJZOUB

REDFORD TOWNSHIP and J. HAAS,
in his individual and official capacities,
Defendants.
CHRISTOPHER TRAINOR & ASSOCIATES
CHRISTOPHER J. TRAINOR (P42449)
AMY J. DEROUIN (P70514)
SHAWN C. CABOT (P64021)
Attorneys for Plaintiff
9750 Highland Road
White Lake, MI 48386
[phone]
[e-mail]

CUMMINGS, McCLOREY, DAVIS &
ACHO, P.L.C.
JEFFREY R. CLARK (P33074)
33900 Schoolcraft Road
Livonia, MI 48150
734-261-2400
734-261-4510-fax
[e-mail]

STIPULATED PROTECTIVE ORDER FOR INDEPENDENT MEDICAL
EXAMINATION OF PLAINTIFF
UPON STIPULATION of the parties and the Court being otherwise fully
advised in the premises;
IT IS HEREBY ORDERED that Plaintiff shall appear for an Independent
Medical Examination on a mutually convenient date, time, and place to be
determined by Counsel for the parties; and which can take place after the courtimposed discovery cut-off date.

IT IS FURTHER ORDERED that Defendants’ Independent Medical
Examiner shall not perform any invasive procedures without the prior consent of
Plaintiff’s Counsel or Order of the Court.
IT IS FURTHER ORDERED that Plaintiff shall be permitted to have his
attorney or other third party of Plaintiff’s choosing present.
IT IS FURTHER ORDERED that Plaintiff’s Counsel shall be provided a
copy of any report(s) generated as a result of Plaintiff’s Independent Medical
Examination.
IT IS FURTHER ORDERED that Plaintiff’s Counsel be permitted to take
the discovery deposition of Defendants’ Independent Medical Examiner prior to
the examiner’s trial testimony.
IT SO ORDERED.
Dated: February 17, 2016
s/Robert H. Cleland
HONORABLE ROBERT H. CLELAND

We hereby stipulate to the above Order:
s/Shawn C. Cabot
Shawn C. Cabot (P64021)
Attorney for Plaintiff

s/Jeffrey R. Clark w-consent
Jeffrey R. Clark (P33074)
Attorney for Defendants