Dotson v. Calvin University et al

10852102.5
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
CHARLES DOTSON, JR.
Plaintiff,
v
CALVIN UNIVERSITY, READY FOR
LIFE, ABIGAIL SOBCZYNSKI, in her
CALVIN UNIVERSITY, READY FOR
LIFE, ABIGAIL SOBCZYNSKI, in her
individual and official capacity as Graduate
Associate and Resident Director and
Coordinator or Ready for Life with Calvin
University, TONI FALK, in her individual
and official capacity as the Program Director
of the Ready for Life Academy and Instructor
with Calvin University, EMILY PERTON, in
her individual and official capacity as
Executive Director with Ready for Life and
Calvin University, LAUREN HORRAS, in
her individual and official capacity as Calvin
University Title IX Coordinator Director of
Safer Spaces, AMY TYRRELL, individually
and as Legal Guardian of LUKAS
TYRRELL, an incapacitated individual, and
DAVID TYRRELL,
Defendants.
Case No.: 1:24-cv-01111-JMB-RSK
District Judge: Jane M. Beckering
Magistrate Judge: Ray Kent
STIPULATED PROTECTIVE
ORDER
ANNA EVE WRIGHT (P72611)
Atnip & Associates, PLLC
Attorney for Plaintiff
400 Water St., Suite 205
Rochester, MI 48307
(248) 266-3847 Fax: (248) 674-4774
Email: anna@atniplawyers.com
HEIDI A. TANNER (P61953)
Heidi A. Tanner, Atty at Law, PLLC
Of Counsel for Plaintiff
4701 Charing Ct.
Castle Rock, CO 80109
(248) 672-5478
Email: attyheiditanner@gmail.com
MARK J. ZAUSMER (P31721)
CAMERON R. GETTO (P57300)
CAITLIN E. MALHIOT (P76606)
Zausmer, P.C.
Attorneys for Defendants Ready for Life,
Toni Falk, and Emily Perton
32255 Northwestern Hwy., Suite 225
Farmington Hills, MI 48334
(248) 851-4111 Fax: (248) 851-0100
Email: mzausmer@zausmer.com
Email: cgetto@zausmer.com
Email: cmalhiot@zausmer.com
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10852102.5
SARAH J. BRUTMAN (P66921)
RANDI DAVIS (P77531)
McDonald Baas & Livingston, PLLC
Attorneys for Defendants Tyrrell
2600 West Big Beaver, Suite 105
Troy, MI 48084
Email: sarah.brutman@mblfirm.com
Email: randi.davis@mclfirm.com
DONALD C. BROWNELL (P48848)
SAJID M. ISLAM (P81829)
Vanderveer Garzia, P.C.
Attorneys for Defendants Calvin University,
Abigail Sobczynski, Lauren Horras
840 W. Long Lake Rd., Suite 600
Troy, MI 48098-6340
(248) 312-2800 Fax: (248) 879-0042
Email: dbrownell@vgpclaw.com
Email: sislam@vgpclaw.com
STIPULATED PROTECTIVE ORDER
The parties’ request for a protective order governing access to Plaintiff’s phone and
downloading and preserving data therefrom is granted as follows:
1. Plaintiff and/or his attorney shall maintain possession of the phone at all
times. During the download, Plaintiff and/or his counsel may be present.
2. SuperiorX Investigations may power the phone up, put it in airplane mode, and
download any and all data from the phone in a non-destructive manner. If the download requires
taking the phone out of airplane mode, the parties shall discuss and attempt to address the issue. If
discussion does not resolve the issue, the parties shall request this court address it.
3. At the conclusion of the download process, the phone shall be powered down and
returned to Plaintiff or his counsel.
4. SuperiorX Investigations shall separate and sequester the data and withhold it from
the parties pursuant to the following terms:
a. Plaintiff’s counsel shall submit a search protocol to SuperiorX Investigations at the
time of the download that is calculated to identify emails, text messages and/or
other communications that are potentially protected by attorney-client
privilege. The search protocol should contain specific names, email addresses,
phone numbers and/or other information calculated to identify confidential
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10852102.5
communications between Plaintiff and his attorneys. The search protocol shall be
made available to defense counsel.
b. SuperiorX Investigations shall use the search protocol submitted by Plaintiff’s
counsel to excerpt the data flagged in the search and provide that data only to
Plaintiff’s counsel.
c. In addition to the data subject to the above search protocol, all data on the phone
pre-dating May 20, 2022 shall be excerpted from the download and provided to
Plaintiff’s counsel.
d. All of the remaining data shall be provided to both Plaintiff’s counsel and all
defense counsel.
5. All of the data obtained from the phone shall be considered
confidential. Confidential information and/or data is subject to the following restrictions:
a. Confidential information shall not be disclosed publicly.
b. Access to confidential information is limited to the attorneys involved in the case,
legal staff at their offices, lay and expert witnesses involved in the case, and persons
participating in depositions in this case.
c. Persons afforded access to confidential data shall be notified that the data is
confidential and not to be used or disclosed except according to the terms of this
protective order.
d. Confidential information shall not be filed with the court in a manner that affords
the public access to the confidential information.
e. If confidential information is used during a deposition in this case, a second,
confidential record shall be created when discussing or using confidential
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information, and the second, confidential record shall be considered confidential
and subject to the protections set forth in this protective order.
f. The parties may agree in writing to remove the confidential designation from some
or all of the data and information in the download and/or depositions subject to this
order.
g. If there is a disagreement regarding whether confidential information should remain
confidential, the parties may bring the matter before the court in a manner
calculated to preserve confidentiality pending a ruling by the court.
6. Documents and material exchanged in the ordinary course of discovery shall not be
rendered confidential merely because the documents and/or material is duplicated in some form
on the phone or in the data on the phone.
7. This protective order shall survive the ultimate disposition of the case. Following
dismissal of this matter, all confidential data, documents and material from the phone shall
be destroyed.
Dated: October 30, 2025 /s/ Ray Kent
RAY KENT
UNITED STATES MAGISTRATE JUDGE
I hereby agree to stipulate to entry of the above Order:
/s/ Heidi A. Tanner (w/consent 10/29/25
ANNA E. WRIGHT (P72611)
HEIDI A. TANNER (P61953)
Attorneys for Plaintiff
/s/ Sajid M. Islam (w/consent 10/29/25)
DONALD BROWNELL (P48848)
SAJID M. ISLAM (P81829)
Attorneys for Defendants Calvin University,
Abigail Sobczynski, and Lauren Horra
/s/ Cameron R. Getto
CAMERON R. GETTO (P57300)
Attorney for Defendants Ready for
Life, Toni Falk, and Emily Perton
/s/ Sarah J. Brutman (w/consent 10/29/25)
SARAH J. BRUTMAN (P66921)
RANDI DAVIS (P77531)
Attorneys for Defendants Tyrell
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