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Parrott v. Marriott International, Inc.

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

January 30, 2018

STEPHANE PARROTT and KEVIN WILLIAMS, Individually and on Behalf of All Other Persons Similarly Situated, Plaintiffs,
v.
MARRIOTT INTERNATIONAL, INC., Defendant.

          Drew Legando Attorney for Plaintiffs 1360

          Derek D. McLeod Jaffe Raitt Heuer & Weiss, P.C.

          CROWELL & MORING LLP Jeffrey L. Poston Andrew W. Bagley Jillian W. Ambrose 1001 Pennsylvania Avenue, N.W. Washington, Attorneys for Defendant

          Mag Judge R. Steven Whalen.

          STIPULATED PROTECTIVE ORDER

          Hon. Victoria A. Roberts U.S. DISTRICT COURT JUDGE

         All the parties to this action have requested that the Court issue a protective order to protect the confidentiality of nonpublic and competitively-sensitive information that may need to be disclosed to adversary parties in connection with discovery in this case pursuant to Fed.R.Civ.P. 26(c), and to guard against the waiver of attorney-client privilege and work product protection pursuant to Fed.R.Evid. 502(d).

         The Parties stipulated, as evidence by the below signature of counsel for all Parties, to the terms of this Protective Order.

         IT IS HEREBY ORDERED that any person subject to this Order - including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order - shall adhere to the following terms, upon a possible penalty of contempt:

         1. Any person subject to this Order who receives from any other person any “Discovery Material” (i.e., information of any kind provided in the course of discovery in this action) that is designated as “Confidential” pursuant to the terms of this Order shall not utilize such Confidential Discovery Material for any purpose other than the prosecution or defense of this litigation or disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder.

         2. Any person may designate as Confidential such portion of such material as consists of:

         a. previously nondisclosed financial information (including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports and sale margins);

         b. previously nondisclosed material relating to ownership or control of any nonpublic company;

         c. previously nondisclosed business plans, product development information, or marketing plans;

         d. confidential business information and communications regarding employee compensation, time ...


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