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Dearborn Plumbing, LLC v. Tymzcak

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

September 5, 2019

DEARBORN PLUMBING, LLC a Michigan limited liability Company, Plaintiff,
v.
MICHAEL TYMZCAK, an Individual BARBARA ASMAR, an individual, and MT DRAINS PLUMBING, INC., a Michigan corporation, Defendants.

          Mark S. Demorest Attorney for Plaintiff

          Johnny A. Hamood Attorney for Defendant Michael Tymzcak and MT Drains Plumbing

          Christopher Stritmatter Attorney for Defendant Asmar

          STIPULATED PROTECTIVE ORDER

          Laurie J. Michelson, United States District Judge

         Pursuant to stipulation of the parties, IT IS HEREBY ORDERED that any party or non-party (the “producing party”) may designate information, documents, or things as “Confidential” under the following terms and conditions:

         1. Any document, information, or thing may be designated “Confidential” if the producing party determines in good faith that it contains confidential or proprietary information.

         2. A producing party may designate any document or other tangible information or thing as “Confidential” by conspicuously stamping or appending the appropriate designation. In the case of a paper document, a producing party may so mark the first page of a multipage document or each applicable page. In the case of an electronic document, a producing party may append to that document the appropriate designation that does not alter the metadata associated with the document, or may place the appropriate designation mark “CONFIDENTIAL” on the outside of the medium (whether disc, hard drive, etc.) containing the document.

         3. A non-producing party may also designate any document, information, or things produced during the course of this proceeding not already designated “Confidential” as “Confidential” as if it were a producing party. The non-producing party shall accomplish such designation by notifying all parties in writing of the specific item so designated.

         4. A producing party may designate documents, information, or things disclosed at a deposition as “Confidential” on the record during the deposition or, within 30 days of receiving the deposition transcript, by notifying all parties in writing of the specific item so designated or the lines and pages of the transcript that are “Confidential.” All deposition transcripts and exhibits will be deemed Confidential for a period of 30 days after the receipt of the deposition transcript.

         a. If a producing party designated such materials as “Confidential” on the record, the court reporter shall indicate that fact on the cover page of the transcript that the transcript includes “Confidential” information, and shall list the pages and line number and/or exhibits of the transcript on or in which such information is contained, and shall bind the transcript in separate portions containing “Confidential” and non-Confidential material. Further, during the period in which such “Confidential” information is discussed during the deposition, any person present during the deposition who is not authorized to receive such information under Paragraph 10 below shall be excluded from that portion of the deposition.

         b. A non-producing party may designate documents, information, or things disclosed at a deposition as “Confidential” in the same manner as a producing party.

         5. If a party producing documents inadvertently fails to mark a document as “Confidential” for which it desires such treatment, it shall so inform the party receiving the documents forthwith, but in no event later than thirty (30) days following discovery of the inadvertent disclosure. The receiving party thereupon shall return the unmarked documents to the producing party and the producing party shall substitute properly marked documents.

         6. The inadvertent or unintentional disclosure by a producing party supplying confidential discovery material, regardless of whether such discovery material was designated as “Confidential, ” shall not be deemed a waiver in whole or in part of the producing party's claim of confidentiality with respect to the discovery material disclosed, provided that the producing party making such inadvertent or unintentional disclosure notifies the receiving parties forthwith, but in no event later than thirty (30) days after it learns of such inadvertent or unintentional disclosure. If discovery material has been disclosed and is subsequently designated as “Confidential, ” the disclosing party shall make good faith efforts to preserve the “Confidential” nature of such discovery material and to obtain compliance with this Order from any person to whom such discovery material was disclosed.

         7. If a producing party, at the time of disclosure, inadvertently fails to identify as “Confidential” any discovery material (including, without limitation, documents, oral, visual, or recorded information) for which it desires such treatment, and another party files the material with the Court prior to receiving notice that such material was inadvertently disclosed without the desired designation, the ...


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