Myers v. City of Jackson et al

Filing 17

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

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
JULIUS MYERS,
Plaintiff,
v.

CASE NO: 2:15-cv-11590
HON: ROBERT H. CLELAND
MAG.: R. STEVEN WHALEN

CITY OF JACKSON, MATTHEW BEARD,
P. GROSS, in their individual and
official capacities,
Defendants.
CHRISTOPHER TRAINOR & ASSOCIATES

PLUNKETT COONEY
AUDREY J. FORBUSH (P41744)
Attorney for Defendants
111 E. Court Street, Ste. 1B
Flint, MI 48502
810-342-7014
810-232-3159-fax
[e-mail]

CHRISTOPHER J. TRAINOR (P42449)
AMY J. DEROUIN (P70514)
SHAWN C. CABOT (P64021)
Attorneys for Plaintiffs
9750 Highland Road
White Lake, MI 48386
[phone]
[e-mail]

STIPULATED PROTECTIVE ORDER
At a session of said Court
held in the City of Detroit,
County of Wayne, State of Michigan
on _September 28, 2015.

PRESENT: HONORABLE ROBERT H. CLELAND
UNITED STATES DISTRICT COURT JUDGE
THIS MATTER having come before this Honorable Court upon stipulation of the
parties, through their respective counsel, and the Court being otherwise fully advised in the
premises:
1 

IT IS HEREBY ORDERED that (1) any citizen complaints filed against Defendants
Matthew Beard and P. Gross; (2) the complete personnel files of Defendants Matthew Beard
and P. Gross without personal information including, but not limited to, addresses, social
security numbers, and names of family members; (3) policies, procedures, and/or guidelines
used to instruct officers on the use of force and taser use and to instruct personnel in the
procedures to be followed in carrying out the duties of their job; and (4) any training records
of Defendants Matthew Beard and P. Gross regarding use of force and the use of tasers shall
be subject to the following conditions:
1.

The documents subject to this protective order shall be used solely and
exclusively for the purposes of the instant lawsuit and can be used in any and
all court filings, judicial proceedings, depositions, alternative dispute
resolution proceedings, trial, and/or any other judicially-related proceedings.

2.

The documents subject to this protective order shall not be used in or for any
other case, proceeding, dispute, or for any commercial, business, or
competitive purpose whatsoever.

3.

The documents subject to this protective order may be reviewed by Counsel
for the parties, Counsels’ staff, those individuals associated with the activities
cited in subparagraph (1), and such experts and/or consultants as Counsel
deems necessary for purposes of this litigation.

4.

The documents provided pursuant to this Protective Order may be disclosed
only to those individuals and/or entities identified in this protective order and
must be used only by those individuals and/or entities identified in this
protective order and must only be used for purposes of this litigation.
2 

IT IS FURTHER ORDERED that nothing in this protective order shall prevent a
party from filing a Motion for Modification of the Protective Order.
IT IS FURTHER ORDERED that this protective order shall survive and remain in
full force and effect until the entry of final judgment (including any appellate proceedings) in
this case, whether by settlement or litigation, unless otherwise ordered by the Court.
IT IS FURTHER ORDERED that the documents produced under this protective
order do not constitute an admission and/or agreement that any such document is admissible
as evidence in this case. Determinations of evidence admissibility will be made by the Court
in a separate proceeding.
IT IS FURTHER ORDERED that the documents produced pursuant to this
protective order shall be destroyed by Plaintiff’s and/or Defendants’ Counsel after final
disposition (including all appeals) of the case except any documents attached to any
pleadings filed with the court, deposition exhibits, or other pleadings.

s/Robert H. Cleland
HONORABLE ROBERT H. CLELAND
We stipulate to entry of the above Order:
s/Amy J. DeRouin
AMY J. DEROUIN (P70514)
Attorney for Plaintiff

s/Audrey J. Forbush w-consent
AUDREY J. FORBUSH (P41744)
Attorney for Defendants

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