United States District Court, E.D. Michigan, Southern Division
Schwartz (by consent) Attorney for Plaintiff.
Charity A. Olson (by consent) Attorney for Merchants &
Medical Credit Corporation, Inc.
E. Fraser Attorney for Defendant Experian Information
AGREED MUTUAL PROTECTIVE ORDER
MATTHEW F. LEITMAN UNITED STATES DISTRICT JUDGE
Defendant Experian Information Solutions, Inc. and Defendant
Merchants & Medical Credit Corporation, Inc. hereby
stipulate and agree to the following Protective Order.
Documents and information have been and may be sought,
produced or exhibited by and among the parties to this action
relating to trade secrets, confidential research,
development, technology and other proprietary information
belonging to the Defendants and/or personal income, credit
and other confidential information of Plaintiff.
parties desire to enter into a mutual agreement regarding the
confidentiality of this information and governing the
production and use of this information.
THEREFORE, this matter having come before the Court and the
Court, being first duly advised, now finds and orders as
Right to Designate Information as
for any party (or for a nonparty witness or deponent which
shall be included in the term “Designating
Party”) may designate as “Confidential” any
document, testimony or other discovery material that contains
confidential commercial or financial information or trade
secret information to which they in good faith believe access
should be limited to litigation counsel presently of record
for the parties, or subsequently substituted.
Definition of “Confidential”
term “Confidential” means information so
designated by a Designating Party in writing (or orally if
recorded as part of a deposition or court record), whether
revealed during a deposition, in a document, in an
interrogatory answer, by production of tangible evidence or
Definition of ...