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Jacobson v. Macomb County Community College

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

December 11, 2017

MARLENE A. JACOBSON, Plaintiff,
v.
MACOMB COUNTY COMMUNITY COLLEGE, Defendant.

          STIPULATED CONFIDENTIALITY PROTECTIVE ORDER

          MATTHEW F. LEITMAN, UNITED STATES DISTRICT JUDGE.

         WHEREAS, parties and 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 (“Discovery Material”) that they consider private, confidential, or proprietary; and

         WHEREAS, Plaintiff Marlene Jacobson and Defendant Macomb County Community College have agreed, through their undersigned attorneys, to set forth procedures for, and rules governing, the use of such Discovery Material;

         1. IT IS ORDERED that 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 party may designate information produced in discovery as “Confidential” material only if the disclosing party determines, in good faith, that such material is: (a) personnel information, including performance ratings, reviews, retirement or separation information, and salary, bonus, benefit and compensation information, of any current or former employee of Defendant; (b) medical information concerning any current or former employee of Defendant and/or their spouses; (iii) information of a proprietary, or confidential business nature, which is not generally known and which an entity would not normally reveal to third parties or, if revealed, would require third parties to maintain in confidence (for example, financial statements and related data; business plans and agreements, and; other similar information).

         2. Documents are to be designated as “Confidential” by stamping each page of the document with the corresponding legend. Deposition testimony may be designated “Confidential” by so indicating orally on the record during the deposition.

         3. 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.

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

         5. 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 of court proceedings;
(c) attorneys (including in-house and outside counsel) of the parties to the Litigation (or the corporate parent of a party to the Litigation) and such attorneys' employees;
(d) parties to the Litigation and their officers, directors, trustees, board members, and managerial employees;
(e) the creator and addressees of such Confidential Material and persons who received a copy thereof (as evidenced on the face of the Confidential Material or another document) prior to its production in the Litigation;
(e) anticipated and actual fact witnesses other than the parties to the Litigation, provided that counsel has a good-faith basis to disclose ...

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