Strand v. Family Fare, LLC et al

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MICHIGAN
CHRISTINA STRAND, an individual,
Plaintiff,
v
FAMILY FARE, LLC d/b/a FOREST HILLS
FOODS, a corporation, and KAREN KEY, an
individual
Defendants.
Case No. 1:25-cv-00733
HON. JANE M. BECKERING
William F. Piper (P38636)
WILLIAM F. PIPER, PLC.
9848 Portage Rd.
Portage, Michigan 49002
269.321.5008
wpiper@wpiperlaw.com
legal@wpiperlaw.com
Attorneys for Plaintiff
Andrea J. Bernard (P49209)
WARNER NORCROSS + JUDD LLP
1500 Warner Building
150 Ottawa Ave., NW
Grand Rapids, Michigan 49503
616.752.2199
abernard@wnj.com
Attorneys for Defendant Family Fare LLC
Michael L. Zamzow (P77808)
ZAMZOW FABIAN PLLC
Suite 220
300 Ottawa Ave., NW
Grand Rapids, Michigan 49503
616.965.2621
michael@zamzowfabian.com
Attorneys for Defendant Karen Key
STIPULATED PROTECTIVE ORDER
The parties, Plaintiff Christina Strand (“Plaintiff”) and Defendants Family Fare, LLC d/b/a
Forest Hills Foods (“Family Fare”) and Karen Key (collectively, “Defendants”), stipulate and
agree to the following:
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1. 	The parties have been and will continue to be engaged in discovery in this case. In
the course of such discovery, Plaintiff has asked Family Fare to produce sensitive and/or
confidential documents and information, including without limitation, personnel information. The
parties further anticipate that ongoing discovery may result in either party to the case being asked
to disclose additional categories of sensitive and/or confidential information. The parties therefore
stipulate to the entry of this Protective Order.
2. 	“Confidential Information” is information which a party, in good faith, regards as
confidential, financial and tax, proprietary, trade secret(s), or other sensitive business or personal
information and shall include, but not be limited to, personal information regarding Family Fare’s
current or former employees.
3. 	A party producing discovery material in this action may designate documents as
confidential and restricted in disclosure under this Order by placing or affixing the word
“Confidential” on the document in a manner that will not interfere with the legibility of the
document. 	For electronic files produced in native format, a party may designate such files as
confidential by affixing the word “Confidential” on the disk or other storage media containing the
electronic files; with respect to any electronic files produced in native format, the “Confidential”
designation applies to the file in its entirety, including all content and metadata. Any other material
containing confidential information that cannot be labeled as “Confidential” shall be placed in a
sealed envelope or other container that is in turn marked “Confidential,” or is otherwise designated
as “Confidential” in a manner agreed upon by the parties. All materials designated as
“Confidential,” including but not limited to, any copies, abstracts, digests, notes, and summaries
thereof, shall be treated as Confidential under the provisions of this Order.
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4. 	Confidential Information produced in this litigation will be used solely for the
preparation, trial, and appeal of this action (including any action to enforce or set aside an award
entered herein), and shall not be used for any other purpose, including, but not limited to, the
preparation or trial of any other action involving these or other parties. Confidential Information
may be disclosed to:
(a) 	Counsel. 	Counsel for the parties, and employees and agents of
counsel, who have responsibility for the preparation and trial of the action;
(b) 	Parties. Parties to the action who have agreed to be bound by this
Order;
(c) 	Consultants, 	Investigators 	and 	Experts. 	Consultants,
investigators and experts retained or consulted by a party or counsel to assist in the
preparation, trial, and appeal of the action;
(d) 	Witnesses. 	Witnesses at, or in preparation for, their testimony in
deposition or trial, in which event such witnesses shall only be shown the
Confidential Information and shall not be allowed to retain copies;
(e) 	Judicial Officers and Court Personnel. 	Judicial officers and
personnel of the United States District Court for the Western District of Michigan;
and
(f) 	Court Reporters and Recorders. Stenographic reporters retained
by the parties to transcribe depositions or other testimony.
Individuals to whom Confidential Information is shown or disclosed pursuant to the
foregoing paragraphs 4(c) and 4(d) shall be advised that the Confidential Information is subject to
this Order and may only be disclosed and used under the terms of this Order.
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5. 	Confidential Information may be used during testimony in discovery depositions
and at the trial of this action, subject to the Federal Rules of Evidence or applicable rulings of the
Court, and may be used by the persons designated in Paragraph 4 to prepare for any trial, hearings,
or depositions held in this action, under the terms of this Order. Counsel for the parties will confer
at least seven (7) days prior to filing with the Court any motions, briefs, or other Court documents
that attach or otherwise incorporate Confidential Information that was disclosed, and labeled as
such, by another party. No party may file Confidential Information under seal without permission
of the Court pursuant to Local Rule 10.6. Prior to the time of trial in this matter, counsel for the
parties will confer with the Court for the purpose of deciding how Confidential Information
introduced into evidence will be treated in the Court record, and what protective instructions will
be given to the jury regarding the Confidential Information.
6. 	Any party may, on the record of any deposition or within twenty (20) days after
receipt of a copy of the transcript, designate all or any portion of the testimony or any exhibit
thereto as Confidential under the terms of this Order, and such testimony or exhibit shall be subject
to the terms of this Order as set forth herein. 	Pending the expiration of such twenty days,
deposition transcripts and exhibits shall be treated as Confidential in their entirety in accordance
with the provisions of this Order.
7. 	Whenever a party objects to the designation of discovery material as Confidential,
counsel for the objecting party shall so notify counsel for the designating party. Within ten (10)
business days of such notification, counsel for the objecting and designating parties shall confer in
good faith in an effort to resolve the matter by agreement. If agreement is not reached, the objecting
party may apply to the Court for a ruling that such discovery material shall not be so treated, giving
notice to the party designating the document. 	Until this Court enters an order changing the
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designation, the discovery material shall be treated as Confidential as originally designated in
accordance with this Order.
8. 	This Confidentiality Order shall not limit or affect any disclosure that is required
by law, rule, or Order issued or promulgated by this Court. If the receiving party is compelled by
any law or order to disclose any Confidential Information in a manner or under terms that would
otherwise violate this Order, the receiving party will use all reasonable efforts to notify the
disclosing party of the obligation, and will provide this notice sufficiently in advance of the
disclosure so that the disclosing party will have a reasonable opportunity to object. Thereafter, the
receiving party shall disclose only the particular Confidential Information it is required to disclose.
9. 	Nothing in this Order shall be intended or construed to limit the manner in which a
producing party may use, disclose, store, or otherwise treat its own Confidential Information for
purposes unrelated to this litigation.
10. 	Nothing herein shall be construed to compel a party to produce information that it
believes to be irrelevant, objectionable or otherwise not subject to discovery pursuant to the
Federal Rules of Civil Procedure.
11. 	The provisions of this Order shall continue in effect with respect to any Confidential
Information unless expressly released by the party who has designated the discovery material as
Confidential, and such effectiveness shall survive the entry of a final judgment in this case. Upon
the conclusion of this litigation, all Confidential Information, other than such material as has been
filed under seal, shall within thirty (30) days either (i) be returned to the producing party, or (ii) at
the option of the receiving party, be destroyed and a certificate of destruction shall be forwarded
to the producing party; provided, however, that counsel for the parties are permitted to retain in
their litigation files copies of briefs, expert reports, and other court submissions, and provided
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further that all such documents containing Confidential Information shall continue to be labeled
and in perpetuity be treated as “Confidential” in accordance with the terms and conditions of this
order. The “Conclusion” of this litigation shall be taken and construed as the date thirty (30) days
following entry of a final, non-appealable order disposing of this action. 	All copies of any
materials designated as Confidential that are provided to any expert witnesses must be retrieved
by counsel for the party who retained the expert, and those materials must be returned to the
producing party or destroyed, as outlined above.
IT IS SO ORDERED.
Dated: February 2, 2026 	/s/ Ray Kent
RAY KENT
United States Magistrate Judge
STIPULATED:
/s/ William F. Piper (w/ permission)
William F. Piper (P38636)
WILLIAM F. PIPER, PLC.
9848 Portage Road
Portage, Michigan 49002
269.321.5008
wpiper@wpiperlaw.com
legal@wpiperlaw.com
Attorneys for Plaintiff
/s/ Daniel S. Brookins
Andrea J. Bernard (P49209)
Daniel S. Brookins (P86665)
WARNER NORCROSS + JUDD LLP
1500 Warner Building
150 Ottawa Ave., NW
Grand Rapids, Michigan 49503
616.752.2199
abernard@wnj.com
dbrookins@wnj.com
Attorneys for Defendant Family Fare LLC
/s/ Michael L. Zamzow (w/ permission)
Michael L. Zamzow (P77808)
ZAMZOW FABIAN PLLC
Suite 220
300 Ottawa Ave., NW
Grand Rapids, Michigan 49503
616.965.2621
michael@zamzowfabian.com
Attorneys for Defendant Karen Key
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