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Cate v. Thetford Corp.

United States District Court, E.D. Michigan, Southern Division

October 4, 2016

JUDITH CATE, Plaintiff,
v.
THETFORD CORPORATION, Defendant.

          Charlotte Croson (P56589) Nacht Law, P.C. Attorneys for Plaintiff

          Noah S. Hurwitz (P74063) Dykema Gossett PLLC Attorneys for Thetford Corporation

          ORDER

          Hon. Robert H. Cleland Judge

         STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         This 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”).

         This 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:

         IT IS ORDERED the following Confidentiality Agreement Protective Order (“Order”) is entered in this case:

         I. CONFIDENTIAL MATERIALS

         A. Definitions

         The term “this Action” means the pending Action captioned Judith Cate v. Thetford Corporation, Case No. 2:16-cv-11703.

         The term “Producer” shall mean any Party or non-party that may produce CONFIDENTIAL MATERIAL in this Action.

         The term “Receiver” shall mean any Party or other person who is subject to this Order that receives CONFIDENTIAL MATERIAL produced in this Action.

         The 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:

         1. those documents produced in response to document requests, subpoenas, or authorizations that any Party to this Action in good faith designates as confidential;

         2. interrogatory answers that any Party to this Action or non-party in good faith designates as confidential;

         3. those portions of deposition transcripts, including exhibits, that any Party to this Action in good faith designates as confidential;

         4. those portions of motions and other pleadings filed with the Court in this Action that any Party to this Action in ...


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