Kelly v. Corizon Health Inc. et al

Filing 12

STIPULATED PROTECTIVE ORDER. Signed by District Judge Terrence G. Berg. (AChu)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
William Kelly
Case No: 2:22-cv-10589
District Judge: Terrence G. Berg
Magistrate Judge: David R. Grand

Plaintiff,
v.
Corizon Health, Inc., et al.
Defendants.
MARGOLIS & CROSS
Ian T. Cross (P83367)
Laurence H. Margolis (P69635)
Attorneys for Plaintiff
214 S. Main St., Suite 200
Ann Arbor, MI 48104
[phone]
[e-mail]
TANOURY, NAUTS, MCKINNEY, &
DWAIHY, PLLC
Paul J. Dwaihy (P66074)
Christopher Kwiecien (P77878)
Attorneys for Todd Bostwick, M.D.
38777 Six Mile Rd., Ste. 101
Livonia, MI 48152
[phone]
[e-mail]
[e-mail]

CHAPMAN LAW GROUP
Jonathan C. Lanesky (P59740)
Nicholas B. Pillow (P83927)
Attorneys for Corizon Health, Inc.,
Quality Correctional Care of Michigan,
Richard Bohjanen, M.D.; Ravi Yarid, D.O.;
Danielle Alford, P.A., Joshua Kocha, P.A.,
and Leila Ghasemi, N.P.
1441 West Long Lake Rd., Suite 310
Troy, MI 48098
[phone]
[e-mail]
[e-mail]

STIPULATED PROTECTIVE ORDER

WHEREAS, Plaintiff has indicated his intent to request in written discovery
that Defendant Corizon Health, Inc., produce certain information and documents in
its actual or constructive possession which Defendants Corizon Health, Inc., Joshua
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Kocha, P.A., Daniel Alford, P.A., Leila Ghasemi, N.P. Dr. Richard Bohjanen, and
Dr. Ravi Yarid (“Corizon Defendants”) consider to be confidential, including, inter
alia, sensitive correctional, personal, medical, and private business operation
information, namely, as follows:


portions of the policy & procedure manuals, quality improvement manuals,
guidelines, orientation materials, and training materials of Corizon;



personal

information,

including

portions

of

personnel

records,

employment/disciplinary files, performance reviews and evaluations of
medical staff;
(collectively “Confidential Information”) and, therefore, the parties have mutually
agreed that the aforementioned Confidential Information should be treated as highly
confidential for reasons including privacy, security, proprietary interests, and
business trade secrets, therefore, have mutually agreed that a protective order
limiting the Confidential Information's use, access, and disclosure should be entered;
and the Court being otherwise fully informed;
IT IS HEREBY ORDERED that, pursuant to Rule 26(c) of the Federal Rules
of Civil Procedure, any party receiving such Confidential Information from Corizon
Defendants, through the discovery process in this case (the Receiving Party) and
such Receiving Party’s counsel will use such Confidential Information only for the
purposes of this Case No. 2:22-cv-10589 (the “Action”) and will keep such
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Confidential Information confidential and will not disclose or disseminate such
Confidential Information except to the following:
i.

Attorneys of record in this Action and secretaries, paralegals, law clerks
and support staff employees to whom, in the opinion of the attorney of
record for the receiving party, it is necessary that the information be
disclosed for purposes of the Action

ii.

Any person who is not an employee or business consultant of a party and
who is retained by a party or its attorneys of record in this Action solely
as an independent expert for the purposes of this Action and who agrees
in writing to be bound by the terms of this Protective Order. The
independent expert must complete and sign a Confidentiality Statement
agreeing to be bound by the terms of this protective order. A copy of that
Confidentiality Statement must be given to Corizon Defendants’ counsel
before access is allowed to the Confidential Information.

iii.

Court reporters, stenographers, clerks, law clerks, and other court
personnel employed by the Court, and court reporters, videographers,
and/or stenographers at depositions.

iv.

All persons specifically engaged by a party for the purpose of supporting
a party’s litigation effort (including, but not limited to firms engaged in
the processing, hosting, and/or facilitating the review of documents
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produced to a party; making photocopies; preparing demonstrative aids
for hearing or trial; conducting or participating in jury studies and/or
research; mediating the parties’ dispute; or conducting case assessments);
so long as each respective vendor or contractor has a confidentiality
agreement in place with retaining counsel or party that would cover the
information in question.
v.

The author or recipient of the document (not including a person who
received the document solely in the course of the Action)

vi.

To a deponent in the course of a deposition, and as necessary to use such
Confidential information in compliance with E.D. Mich. LR 26.4(b).

vii.

The Court and its personnel.

This Order shall survive the termination of this action, and shall remain in
effect until modified, superseded, or terminated by order of the Court or by
agreement of the parties.
Any person who violates this Order may be subject to sanctions, including
injunctive relief, contempt orders, monetary damages, or other penalties to be
determine by the Court.
This document does not authorize the filing of any documents under seal.
Documents may be sealed only if authorized by statute, rule, or order of the Court.
IT IS SO ORDERED.
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/s/Terrence G. Berg____________
Terrence G. Berg
United States District Judge
Dated: May 9, 2022
Respectfully Submitted,
/s/ Laurence H. Margolis (w/permission)
MARGOLIS & CROSS
Ian T. Cross (P83367)
Laurence H. Margolis (P69635)
Attorneys for Plaintiff
214 S. Main St., Suite 200
Ann Arbor, MI 48104
[phone]
[e-mail]
/s/ Nicholas B. Pillow
CHAPMAN LAW GROUP
Jonathan C. Lanesky (P59740)
Nicholas B. Pillow (P83927)
Attorneys for Corizon Health, Inc.,
Quality Correctional Care of Michigan,
Richard Bohjanen, M.D.; Ravi Yarid, D.O.;
Danielle Alford, P.A., Joshua Kocha, P.A.,
and Leila Ghasemi, N.P.
1441 West Long Lake Rd., Suite 310
Troy, MI 48098
[phone]
[e-mail]
[e-mail]
/s/ Christopher Kwiecien (w/ permission)
TANOURY, NAUTS, MCKINNEY, &
DWAIHY, PLLC
Paul J. Dwaihy (P66074)
Christopher Kwiecien (P77878)
Attorneys for Todd Bostwick, M.D.
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38777 Six Mile Rd., Ste. 101
Livonia, MI 48152
[phone]
[e-mail]
[e-mail]

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