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Abaas v. Hewlett Packard Enterprise Co.

United States District Court, E.D. Michigan

April 13, 2017

RAMY A. ABAAS, Plaintiff,
v.
HEWLETT PACKARD ENTERPRISE COMPANY, Defendant.

          BURGESS SHARP & GOLDEN PLLC ATTORNEYS FOR PLAINTIFF

          LITTLER MENDELSON, P.C. ATTORNEYS FOR DEFENDANT

          STIPULATED PROTECTIVE ORDER

          TERRENCE G. BERG UNITED STATES DISTRICT JUDGE

         WHEREAS, the parties in the above-captioned matter have agreed that these proceedings may involve the discovery and use of confidential, non-public, sensitive, or proprietary business, employment, tax, financial, and personally identifiable information, documents and other materials;

         WHEREAS, the parties have agreed to produce such documents only on the agreement that such “Confidential Information, ” meaning current and former Hewlett-Packard Company (“HP”) or Hewlett Packard Enterprise Company (“HPE”) employee social security information, dates of birth, personal banking information, medical information, personnel records and records stating the actual rates of pay at HP or HPE, and “Trade Secrets, ” meaning HP's or HPE's corporate trade secrets, nonpublic research and development data, pricing formulas, prospective inventory management programs, confidential business information not generally known to the general public, and customer-related information, will be disclosed only as provided herein;

         WHEREAS, the parties have agreed to stipulate to protect certain confidential and otherwise protected documents, data (including electronically stored information), and other information (collectively “Documents”), against claims of waiver and inadvertent production in the event they are produced during the course of this litigation whether pursuant to a Court Order, a parties' discovery request, or informal production;

         WHEREAS, both parties may be required to produce large volumes of Documents, the parties wish to comply with discovery deadlines and complete discovery as expeditiously as possible, while preserving and without waiving any evidentiary protections or privileges applicable to the information contained in the Documents produced, including as against third parties and other proceedings, and in addition to their agreement, need the additional protections of a Court Order under FRE 502 (d) and (e) to do so;

         WHEREAS, in order to comply with applicable discovery deadlines, a party may be required to produce certain categories of Documents that have been subject to minimal or no attorney review (the “Disclosures”). This Stipulation and Order is designed to foreclose any arguments that by making such Disclosures, the disclosure or production of Documents subject to a legally recognized claim of privilege, including without limitation the attorney-client privilege, work-product doctrine, or other applicable privilege:

(a) was not inadvertent by the Producing Party;
(b) that the Producing Party did not take reasonable steps to prevent the disclosure of privileged Documents;
(c) that the Producing Party did not take reasonable or timely steps to rectify such Disclosure; and/or
(d) that such Disclosure acts as a waiver of applicable privileges or protections associated with such Documents.

         WHEREAS, because the purpose of this Stipulation is to protect and preserve privileged Documents, the parties agree they are bound as follows from and after the date their counsel have signed it, even if such execution occurs prior to Court approval.

         THEREFORE, the parties seek the entry of an Order, pursuant to Federal Rule of Civil Procedure 26(c) governing the disclosure of documents and information therein pertaining to “Confidential Information, ” “Personal Information, ” and “Trade Secrets” on the terms set forth herein, as well as an Order governing the return of inadvertently produced documents and data and affording them the protections of FRE 502 (d) and (e), on the terms set forth herein.

         IT IS HEREBY STIPULATED AND AGREED THAT:

         1. The Protective Order shall be entered pursuant to the Federal Rules of Civil Procedure and FRE 502 (d) and (e).

         2. The Protective Order shall govern all materials deemed to be “Confidential Information.” Such Confidential Information shall include the following:

(a) Any and all documents referring or related to confidential and proprietary human resources or business information; financial records of the parties; compensation of current or former personnel; policies, procedures or training materials of HP ...

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