Davis v. Wayne State University et al

Filing 22

STIPULATED PROTECTIVE ORDER. Signed by District Judge Mark A Goldsmith. (Goltz, D)

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ROBERT Z. DAVIS, Plaintiff, v. WAYNE STATE UNIVERSITY and WAYNE STATE UNIVERSITY PHYSICIANS GROUP, Defendants. THE KIENBAUM LAW GROUP, P.C. By: Karen S. Kienbaum (P25283) Attorneys for Plaintiff 400 Monroe Street, Suite 470 Detroit, MI 48226 [phone]; fax [phone] WAYNE STATE UNIVERSITY By: Linda M. Galante (P35914) Attorney for Defendant Wayne State University Wayne State University Office of General Counsel 656 W. Kirby, Suite 4259 F.A.B. Detroit, MI 48202 [phone]; fax [phone] HALL RENDER KILLIAN HEATH & LYMAN, PLLC By: Bruce M. Bagdady (P40476) By: Jonathon A. Rabin (P57145) Attorneys for Defendant WSUPG 201 West Big Beaver Road, Suite 1200 Troy, MI 48084 [phone]; fax [phone] Case No. 10-13425 Hon. Mark A. Goldsmith

_____________________________________________________________________________/ STIPULATED PROTECTIVE ORDER This matter having come before the Court upon the stipulation of the parties, wherein they seek a Protective Order preserving the confidentiality of certain documents produced in this litigation, and the Court having reviewed the parties' stipulation and being fully advised in the premises;

NOW, IT IS HEREBY ORDERED: 1. All records of the kind referenced below, shall be protected by this Order and may This applies to the documents

be used solely in connection with the instant litigation. themselves, and the information contained in the documents. a. Plaintiff's tax returns and schedules, b. Plaintiff's medical records, and c. Defendants' corporate documents. 2.

The parties shall not make any such confidential document, or the information

contained therein, available to any person except: a. Attorneys engaged or employed by the parties in the litigation of this action; b. Support staff for the attorneys referenced in 2(a) as deemed necessary by the attorneys for preparation and use during litigation; c. Mediators, facilitators, arbitrators, or case evaluation panels and their staff; d. Expert witnesses consulted or retained by a party; or e. As otherwise provided in this or further Orders of the Court. When any documents are disclosed to the above described persons, the attorneys shall advise such persons that the documents are confidential and subject to the terms of this Order and shall provide such persons with a copy of this Order together with the disclosed documents. 3. Nothing in Paragraph 2 (with the exception of the Court's determination in

accordance with Paragraph 4) shall prevent the parties from using the confidential documents, or information contained therein, at any proceeding in this action such as, but not limited to: a. Discovery depositions;

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b. Motions, briefs and pleadings; c. Any form of facilitative mediation; d. Argument before the Court; and e. Trial or appeal. 4. The parties are bound by the Rules governing the redaction of electronically filed

records, including Social Security numbers, names of minor children, financial account numbers, and dates of birth. 5. Upon the conclusion of this action by settlement, trial, any appeal therefrom, or

upon further Order of the Court, all such documents shall remain confidential and cannot be used by the parties for any manner inconsistent with this Order. SO ORDERED. Dated: December 20, 2010 s/Mark A. Goldsmith MARK A. GOLDSMITH United States District Judge CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was served upon counsel of record and any unrepresented parties via the Court=s ECF System to their respective email or First Class U.S. mail addresses disclosed on the Notice of Electronic Filing on December 20, 2010. s/Deborah J. Goltz DEBORAH J. GOLTZ Case Manager

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We hereby stipulate to the content and form of the above Order.

/s/ Karen S. Kienbaum______________ THE KIENBAUM LAW GROUP, P.C. By: Karen S. Kienbaum (P25283) Attorney for Plaintiff 400 Monroe Street, Suite 470 Detroit, MI 48226 313-967-0700; fax [phone] [e-mail]

/s/ Jonathan Rabin (with consent)_____
HALL RENDER KILLIAN HEATH & LYMAN, PLLC

Bruce M. Bagdady (P40476) Jonathan A. Rabin (P57145) Attorneys for Defendant WSUPG 201 West Big Beaver Road, Suite 1200 Troy, MI 48084 248-740-7505 [e-mail] /s/ Linda Galante (with consent)____ Wayne State University Office of the General Counsel Linda M. Galante (P35914) Attorney for Defendant WSU 656 W. Kirby, 4249 F.A.B. Detroit, MI 48202 313-577-2268; fax [phone] [e-mail]

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