United States District Court, E.D. Michigan, Southern Division
STEPHANE PARROTT and KEVIN WILLIAMS, Individually and on Behalf of All Other Persons Similarly Situated, Plaintiffs,
MARRIOTT INTERNATIONAL, INC., Defendant.
Legando Attorney for Plaintiffs 1360
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
Judge R. Steven Whalen.
STIPULATED PROTECTIVE ORDER
Victoria A. Roberts U.S. DISTRICT COURT JUDGE
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).
Parties stipulated, as evidence by the below signature of
counsel for all Parties, to the terms of this Protective
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:
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.
person may designate as Confidential such portion of such
material as consists of:
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);
previously nondisclosed material relating to ownership or
control of any nonpublic company;
previously nondisclosed business plans, product development
information, or marketing plans;
confidential business information and communications
regarding employee compensation, time ...