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Raleigh v. Service Employees International Union

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

August 23, 2019

MARK RALEIGH, Plaintiff,
v.
SERVICE EMPLOYEES INTERNATIONAL UNION, Defendant.

          Raymond J. Sterling, Brian J. Farrar Sterling Attorneys at Law, P.C. Attorneys for Plaintiff

          Kathleen M. Keller, April H. Pullium Bredhoff & Kaiser PLLC Heather Cummings Cummings & Cummings Law Group, PLLC

          David Grand, Magistrate Judge.

          STIPULATED PROTECTIVE ORDER

          TERRENCE G. BERG, UNITED STATES DISTRICT JUDGE.

         Upon considering the stipulation of the parties, and this Court being fully apprised therein, this Court finds that a Protective Order regarding private, confidential, and/or proprietary information should be entered in this matter, and accordingly, IT IS ORDERED that:

         1. This Protective Order is hereby entered in this matter and governs certain designated documents, testimony, information, and other written discovery (“Discovery Material”) to be exchanged by the parties, Plaintiff Mark Raleigh and Defendant Service Employees International Union (“SEIU”) and by any non-parties requested to produce Discovery Material in this action (“Litigation”) that the producing party or non-party considers to be private, confidential, or proprietary.

         2. All Discovery Material designated as “Confidential” when it is produced, or designated as “Confidential” during any depositions taken during the Litigation, shall (unless the “Confidential” designation is voluntarily withdrawn or stricken by Order of this Court) be used solely for purposes of the Litigation and for no other purpose, except that material designated as “Confidential” may be used for purposes of the litigation in Fells v. SEIU, No. 2019 CA 3079 B (D.C. Superior Court) (“Fells Litigation”) to the same extent to which it may be used in this Litigation. All Discovery Material designated as “Confidential-Raleigh Only” when it is produced, or designated as “Confidential-Raleigh Only” during any depositions taken during the Litigation, shall (unless the “Confidential-Raleigh Only” designation is voluntarily withdrawn or stricken by Order of this Court) be used solely for purposes of the Litigation and for no other purpose; such material may not be used in the Fells Litigation. If, in the course of discovery or other proceedings in this Litigation, Defendants 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” or “Confidential-Raleigh Only.” A party may designate information produced in discovery as “Confidential” or “Confidential-Raleigh Only” material only if the disclosing party determines, in good faith, that such material is: (a) private personnel information, including performance ratings, reviews, retirement or separation information, and salary, benefit and compensation information, of any current or former employee of any party to this litigation; (b) confidential personal, medical, or financial data concerning Plaintiff, any relative of Plaintiff, or any current or former officer and/or employee of SEIU and/or their spouses; or (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, member information, business/organizing plans and agreements, and other similar information). In addition, a party may designate information produced in discovery as “Confidential-Raleigh Only” material only if the disclosing party determines, in good faith, that such material pertains only to the Raleigh Litigation and is inappropriate for disclosure in the Fells Litigation. Examples of such material include, but are not limited to, documents reflecting confidential statements or information from witnesses that were obtained in the investigation of Plaintiff Raleigh, but not Plaintiff Fells; and documents reflecting confidential organizing and other information in work assignments completed by Plaintiff Raleigh

         3. Documents and other written discovery shall be designated as “Confidential” or “Confidential-Raleigh Only” by stamping each page of the document with the corresponding legend. Deposition testimony shall be designated “Confidential” or “Confidential-Raleigh Only” by so indicating orally on the record during the deposition. The designated pages of the transcript of any such deposition shall be marked by the court reporter with the appropriate legend.

         4. Any person in possession of Confidential 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.

         5. Confidential Discovery Material shall not be disclosed to third parties who are not litigants in this case or their counsel, except as provided in paragraph 6, except upon prior written consent of the designating party.

         6. 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 ...

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