United States District Court, E.D. Michigan, Southern Division
Charlotte Croson (P56589) Nacht Law, P.C. Attorneys for
S. Hurwitz (P74063) Dykema Gossett PLLC Attorneys for
Robert H. Cleland Judge
CONFIDENTIALITY AGREEMENT AND PROTECTIVE
Stipulated Confidentiality Agreement and Protective Order is
entered into by and among Defendant Thetford Corporation and
Plaintiff Judith Cate (collectively the “Parties”
or separately as a “Party”).
matter having come before the Court on the Parties'
stipulation, due notice having been given, and the Court
being otherwise fully advised on the premises:
ORDERED the following Confidentiality Agreement Protective
Order (“Order”) is entered in this case:
term “this Action” means the pending Action
captioned Judith Cate v. Thetford Corporation, Case No.
term “Producer” shall mean any Party or non-party
that may produce CONFIDENTIAL MATERIAL in this Action.
term “Receiver” shall mean any Party or other
person who is subject to this Order that receives
CONFIDENTIAL MATERIAL produced in this Action.
term “CONFIDENTIAL MATERIAL” means all documents
(including the information contained in those documents) and
other information (including testimony) a Producer Party in
good faith designates as CONFIDENTIAL MATERIAL. CONFIDENTIAL
MATERIAL shall include, without limitation, the following
documents and materials:
those documents produced in response to document requests,
subpoenas, or authorizations that any Party to this Action in
good faith designates as confidential;
interrogatory answers that any Party to this Action or
non-party in good faith designates as confidential;
those portions of deposition transcripts, including exhibits,
that any Party to this Action in good faith designates as
those portions of motions and other pleadings filed with the
Court in this Action that any Party to this Action in ...