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Davies v. Goebel

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

July 13, 2017

DET. MATT GOEBEL, et al., Defendants.

          FIEGER, FIEGER, KENNY & HARRINGTON, P.C. GINA U. PUZZUOLI Attorneys for Plaintiff

          CITY OF DETROIT LAW DEPARTMENT CHRISTINA V. KENNEDY Attorney for Defendant Mendoza;

          POTTER, DeAGOSTINO, O'DEA & PATTERSON ROBERT C. CLARK Attorney for Oakland County



         This matter having come before this Honorable Court upon stipulation of the parties, through their respective counsel, and the Court being otherwise fully advised in the premises:


         1. Each of the parties to this action upon whom or which a discovery request, including a subpoena duces tecum, has been or shall be served by any party to this action may designate as “confidential” any documents produced, when such materials refer or relate to, or would otherwise disclose, information of a personal, proprietary or confidential business nature as defined below.

(a) “Confidential” is defined as any type or classification of information, whether originals, copies, or in redacted form, or whether in oral deposition testimony (transcript or videotape), interrogatory responses or responses to request for admission, consisting of business or financial records, Plaintiff's medical or psychiatric records, confidential department files (including portions thereof) and any other personal documents or information of the parties or their employees, and any other writing as defined by the Federal Rules of Evidence, reflecting confidential, commercial or personal information that counsel for any of the parties has in good faith designated as confidential. This paragraph does not prohibit the parties from claiming a privilege and does not waive any party's right to assert a privilege and to not produce such document.

         2. Material designated “confidential” shall be used by the party receiving the material solely in the prosecution or defense of this action.

         3. Material designated as “confidential” shall be held in confidence by the party requesting the documents and his/her/its representatives; counsel for that party and professional, clerical, secretarial or other support personnel of such counsel; a person not an attorney retained by that party or counsel to assist in litigation such as accountants and experts, court reporters retained in connection with depositions in this litigation; and witnesses at deposition (collectively, the “receiving party”); none of whom shall permit disclosure of the documents, except purposes necessary to this litigation. The receiving party shall neither grant nor permit any other person to have access to any material designated as “confidential, ” or inform any other person of the existence of such material or of any of the contents thereof without submitting this order to the receiving person .

         4. The inadvertent disclosure or production by any party of any document protected by the attorney client or other privilege or by the attorney work product doctrine shall not constitute, be construed as, or have the effect of a waiver of such privilege or protection.

         5. “Confidential” material marked as an exhibit in a deposition or other discovery document remains confidential, and may not be disclosed by the receiving party except in accordance with this order.

         6. The parties agree that any documents that have been designated as confidential that are used during a deposition will be treated in accordance with the stipulated protective order. By entering into this protective order, Defendants do not waive the right to file a motion for a protective order to have any portions of a deposition transcript marked as “confidential” but must do so within 21 days of the date the deposition was taken.

         7. The provisions set forth in paragraph three (3) above apply for a party's designation or assertion of the deliberative process privilege. To the extent such a designation and/or privilege is asserted, the party asserting the designation/privilege shall provide the basis for its assertion. To the extent the party asserts that the privilege precludes the production of documents and/or material, the asserting party shall produce a privilege log to all parties. Any disciplinary records contained in these files will be redacted to remove privileged information, such as conclusions of investigators or disciplinary actions, pursuant to the executive / deliberative process privilege. ...

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