Anderson v. Ascension Borgess Hospital

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UNITED STATES DISTRICT COURT
IN THE WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
DENIECE ANDERSON,
an individual,
Plaintiff,
v.
ASCENSION BORGESS HOSPITAL,
a non-profit corporation,
Defendant.
CASE NO. 25-cv-00911
HON. HALA Y. JARBOU
MAGISTRATE JUDGE RAY KENT
WILLIAM F. PIPER, P.L.C.
William F. Piper (P38636)
Attorney for Plaintiff
9848 Portage Rd.
Portage, MI 49002
(269) 321-5008
Fax: (269) 321-5009
wpiper@wpiperlaw.com
legal@wpiperlaw.com
JACKSON LEWIS P.C.
Timothy J. Ryan (P40990)
Linda L. Ryan (P67686)
Attorneys for Defendant
6011 West River Drive NE
Suite B
Belmont, MI 49306
(616) 940 0230
timothy.ryan@jacksonlewis.com
linda.ryan@jacksonlewis.com
STIPULATED CONFIDENTIALITY PROTECTIVE ORDER
WHEREAS, parties and non-parties to this action ("Litigation"), have been or may be
requested during 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 Ascension Borgess Hospital, (“Defendant”), through its counsel,
and Plaintiff Deniece Anderson ("Plaintiff") have agreed, by their undersigned attorneys, to set
forth procedures for, and rules governing, the use of such Discovery Material;
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1. IT IS ORDERED that all Discovery Material produced, in the Litigation, shall be
used solely for the purposes of the Litigation and for no other purpose shall not be disclosed except
as provided in paragraph 2.
2. 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 Litigation) and such
attorneys' employees;
(d) parties to the Litigation and their officers, directors, trustees, and
employees;
(e) the creator and addressees of such Confidential Material and persons who
received a copy thereof prior to its production in the Litigation;
(f) anticipated and actual fact witnesses other than the parties to the Litigation,
provided that counsel has a good-faith basis to disclose such information to
such witness;
(g) experts, advisors, consultants, and other persons engaged to assist directly
in the Litigation;
(h) mediators; and
(i) as may be required by law, court order or subpoena.
IT IS SO ORDERED.
Dated: February 2, 2026
RAY KENT
United States Magistrate Judge
/s/ Ray Kent
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WE HEREBY STIPULATE TO THE ENTRY OF THE ABOVE ORDER:
WILLIAM F. PIPER, P.L.C.
/s/ William F. Piper (with Consent)
William F. Piper (P38636)
Attorney for Plaintiff
9848 Portage Road
Portage, MI 49002
(269) 321-5008
wpiper@wpiperlaw.com
Dated: January 27, 2026
JACKSON LEWIS P.C.
/s/ Linda L. Ryan
Timothy J. Ryan (P40990)
Linda L. Ryan (P67686)
Attorneys for Defendant
6011 West River Drive NE, Suite B
Belmont, MI 49306
(616) 940 0230
timothy.ryan@jacksonlewis.com
linda.ryan@jacksonlewis.com
Dated: January 27, 2026
4897-0257-9595, v. 1
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