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Caudle v. Hard Drive Express, Inc.

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

August 20, 2019

STEPHEN CAUDLE, Plaintiff,
v.
HARD DRIVE EXPRESS, INC. and JAMES BETZ, Defendants.

          MILLER COHEN, PLC Keith Flynn (P74192) Judy A. Champa (P57489) Attorneys for Plaintiff

          VINING LAW GROUP, PLC Guy C. Vining (P27892) Attorney for Defendants

          Mona K. Majzoub Magistrate Judge

          STIPULATED CONFIDENTIALITY PROTECTIVE ORDER

          TERRENCE G. BERG 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, Defendant Hard Drive Express, Inc. (“HDE” or “Defendant”), by and through its counsel, and Plaintiff Stephen Caudle (“Plaintiff”) have agreed, by their undersigned attorneys, to set forth procedures for, and rules governing, the use of such Discovery Material;

         1. IT IS ORDERED that all 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 action, Defendant or Plaintiff or any party to the Litigation, or any third party discloses Discovery Material they deem private, confidential, or proprietary, the producing entity may designate such Discovery Material as "Confidential." Discovery Material designated as Confidential, and all copies, summaries, or extracts thereof, shall be referred to herein as "Confidential Material," and shall be subject to all the terms of this Stipulation and Protective Order ("Order"). A producing party may also designate Discovery Material for "confidential," where appropriate.

         2. Documents may be designated “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, or by subsequent designation in writing by the deponent or his/her attorney, or an attorney for any party. The designated pages of the transcript of any such deposition shall be marked by the court reporter with the appropriate legend.

         3. Any person in possession of Discovery 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 paragraphs 5 and 6 below, except upon prior written consent of the designating party.

         5. Confidential Material 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 ...

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