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AES-Apex Employer Services, Inc. v. Rotondo

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

December 12, 2017

AES-APEX EMPLOYER SERVICES, INC. and AES-APEX EMPLOYER SOLUTIONS, INC., Plaintiffs,
v.
DINO ROTONDO, RICHARD MARK, and UNITED STATES, DEPARTMENT OF TREASURY - INTERNAL REVENUE SERVICE, Defendants, and AKOURI INVESTMENTS, LLC Intervening Party.

          DAVID B. TIMMIS, DAVID Q. HOUBECK, Attorneys for Plaintiffs.

          ERIC M. NEMETH, BRADLEY S. DEFOE, Attorneys for Defs. Mark & ABO-Mark.

          ROBERT J. WILLE Trial Attorney, Tax Division United States Department of Justice Attorneys for Defendant United States

          EVAN H. KAPLOE Attorney for Def. Dino Rotondo.

          PRESENT: Robert H. Cleland

          STIPULATED PROTECTIVE ORDER

          ROBERT H. CLELAND UNITED STATES DISTRICT JUDGE.

         This matter having come before this Honorable Court pursuant to the stipulation of the parties; and the Court being otherwise fully advised in the premises:

         IT IS HEREBY ORDERED that any and all source data and/or financial information provided by the Plaintiffs relating to the customer accounts which are the subject of the Consulting Fees at issue in the present matter, as well as any and all ancillary financial information or figures provided in connection with the production of said information, will be produced and/or provided subject to the following conditions:

         2. In the event that a party producing information makes a determination that there is a need for additional confidentiality and/or restrictions with regard to specific items among the produced information, the producing party may designate said information “Attorney's Eyes Only, ” which designation shall prevent the dissemination of said information by the receiving party to any individual other than the attorneys for the receiving party (including, in the case of the United States, any other attorneys of the Department of Justice, Tax Division, and/or the Office of Chief Counsel to the Internal Revenue Service assisting with this case). Such designation shall include an explanation as to why the designating party believes that additional confidentiality and/or restrictions are necessary. In the event that the receiving party objects and/or takes exception with the “Attorney's Eyes Only” designation, the receiving party shall seek a determination from the Court relating to the “Attorney's Eyes Only” designation, and the burden shall be on the designating party to justify the additional restriction. In the interest of avoiding disputes that may turn out to be academic, the failure to assert an objection shall not waive the right to assert one and seek a court ruling at any subsequent time.

         4. In the event that a party who has received information subject to this Protective Order intends to include said information in a filing with the Court or otherwise submit said information to the Court, said filing and/or submission shall be made “under seal”, either in an envelope or enclosure clearly marked “SUBJECT TO PROTECTIVE ORDER”, along with the present STIPULATED PROTECTIVE ORDER included in said envelope and/or enclosure, or consistent with other procedures available for sealed filings pursuant to local rules and the Court's ECF system. Nothing herein shall prevent the Court from determining that the information filed does not merit sealing and thereupon unsealing the information on its own motion or at the request of any party.

         6. This Order shall survive the final termination of this action. Following the resolution or final disposition of this matter, and upon the request of the producing party within 14 days from the date of the entry of the final order of disposition (after any appeals), with the exception of Defendant Dino Rotondo, or his duly retained attorney, counsel for the receiving party shall assemble and return to the producing party all information designated as confidential or “Attorneys' Eyes Only, ” which production shall be made within 14 days of the request. In the event that there is no request for the return of information designated as confidential or “Attorneys' Eyes Only, ” the receiving party shall destroy all such information, including copies of same, within 28 days from the entry of the final order of disposition. The Court shall retain jurisdiction to entertain such further proceedings and to enter further Orders and Judgments as may be necessary or appropriate to implement and/or enforce the provisions of this Order, or modify this Order as it concludes may be appropriate. This paragraph shall not be construed to require the United States to return ...


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