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Trustees of Detroit Carpenters Fringe Benefit Funds v. TRI-Crossing Installation Services, Inc.

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

October 10, 2017

TRUSTEES OF THE DETROIT CARPENTERS FRINGE BENEFITS FUNDS, Plaintiff,
v.
TRI-CROSSING INSTALLATION SERVICES, INC., A MI CORPORATION AND SYNERGY INSTALLATION SOLUTIONS, LLC, A SOUTH CAROLINA LIMITED LIABILITY COMPANY, JOINTLY AND SEVERALLY Defendant.

          Walter B. Fisher, Jr. (P51337) Attorneys for Plaintiffs, Kickham Hanley PLLC

          Jamie K. Warrow (P61521) Attorneys for Synergy Installation Solutions, Ogletree, Deakins, Nash, Smoak & Stewart, PLLC

          William E. Pilchak (P29545) Attorneys for Tri-Crossing Installation Services, Inc.

          STIPULATED CONFIDENTIALITY PROTECTIVE ORDER

          Hon. John Corbett O'Meara, United States District Court Judge

         WHEREAS, parties and potentially non-parties to this action ("Litigation") have been or may be requested in the course of discovery or other proceedings to produce or disclose testimony, documents, or other information that they consider confidential and/or proprietary ("Confidential Discovery Material"); and

         WHEREAS, Plaintiffs, Trustees of the Detroit Carpenters Fringe Benefit Funds, ("Plaintiffs") and Defendants, Tri-Crossing installation Services, Inc. and Synergy Installation Solutions, LLC ("Defendants") have agreed, through their undersigned attorneys, to set forth procedures for, and rules governing, the use of such Confidential Discovery Material;

         1. All Confidential Discovery Material produced, or depositions taken in discovery in the Litigation, shall be used solely for purposes of the Litigation and for no other purpose. If, in the course of discovery or other proceedings in this Litigation, Defendant or Plaintiff, any party to the Litigation, or any third-party discloses Discovery Material they deem confidential, or proprietary, the producing party may designate such Discovery Material as "Confidential." A disclosing party may designate information produced in discovery as Confidential Material only if the disclosing party determines, in good faith, that such material constitutes: (a) trade secrets; (b) information of a confidential or proprietary nature; (c) Defendant's financial or tax information; and/or (d) any other information in which any party or any third-party has a reasonable expectation of privacy (such as personally identifiable information, health information, etc.).

         2. Documents are to be designated as "Confidential" by the producing party stamping each page of the document with the corresponding legend or in the instance where original records are copied by an opposing party, a written or electronic designation of confidentiality to the copying party by the party producing original records; however, the inadvertent failure to stamp covered pages or documents "Confidential" in no way alters or waives the protected and confidential nature of the Confidential Material or documents and does not remove them from the protection of this Order. If the Discovery Material is marked, the parties will ensure that the marking shall not cover or block the substance of the Confidential Discovery Material in any way. Further, all parties agree that they will not seek to use the documents marked "Confidential" at trial, but will permit the producing party to substitute "clean" copies for the marked copies. Deposition testimony may be designated "Confidential" by so indicating orally on the record during the deposition or designating such testimony as confidential at a reasonable time after the deposition or receipt of the transcript.

         3. In the event that a document is produced without the designation "Confidential" and it is later determined, in good faith, that such a designation should have appeared on the document, the designating party may restrict future disclosure of the document, consistent with this Protective Order, by notifying the receiving party in writing of the change in, or addition of, a restrictive designation. The notice shall include a description of the document and the designation under which future disclosure of the document is to be governed.

         4. Any person in possession of Confidential Material shall maintain it in a reasonable and appropriate manner so as to avoid disclosure of its contents in any manner not permitted by this Order.

         5. Confidential Material shall not be disclosed, except as provided in paragraph 6, except upon prior written consent of the designating party.

         6. Discovery Material that is designated "Confidential" may be disclosed only to the extent reasonably necessary for the conduct of the Litigation and only to the following:

(a) the Court (including any appellate court) and Court personnel;
(b) court reporters in connection with the taking of a deposition or the transcription ...

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