Thomas v. McLaren Greater Lansing

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN
DALE THOMAS,
Plaintiff, Case No. 1:25-cv-01234
v. Hon. Jane M. Beckering
MCLAREN GREATER LANSING,
A foreign limited liability company,
Defendant.
/
STIPULATED PROTECTIVE ORDER
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The parties agree that discovery proceedings in this case may involve documents
and testimony containing information that is subject to the protection of the Court under Fed. R.
Civ. P. 26(c). The parties stipulate and agree that that the following protective provisions shall
govern the handling of testimony, information, and documents produced or obtained by the parties:
1. Confidential Information
A. This Protective Order shall apply to all information produced by either party during
discovery in this case that is marked “CONFIDENTIAL.”
B. Designation: Each party shall have the right to designate as confidential and subject
to this Protective Order any thing, information, document, or portion of any
document produced or prepared by it which the producing party deems to contain
information that is confidential. Material that may be designated as confidential
includes but is not limited to personnel records or personal information of
individuals who are not a party to this lawsuit; compensation information;
employee benefit information; financial and tax information; “health information,”
“protected health information,” and “individually identifiable health information,”
as those terms are defined and used by the Health Portability and Accountability
Act of 1996 (“HIPAA”) and its regulations; and confidential commercial
information. Designations shall be made in good faith. This designation shall be
made by stamping each page of a document containing Confidential Information
with the legend “CONFIDENTIAL” at or before the time the document is produced
to the receiving party. Any party may designate deposition testimony s
confidential, in which case the pages of the transcript with the confidential
testimony shall be marked “CONFIDENTIAL.”
C. Redactions: Each party that designates as confidential and subject to this Protective
Order any thing, information, or document that is protected by HIPAA or its
regulations may redact any health information, protected health information, or
individually identifiable health information of individuals who are not parties to
this case or otherwise involved in this case.
D. Inadvertent Production: In the event that a party inadvertently produces
Confidential Information without the “CONFIDENTIAL” legend, the producing
party shall, promptly upon discovery of the inadvertent production, provide the
receiving party with (i) written notice that the Confidential Information is
designated Confidential under this Protective Order and (ii) replacement copies of
the Confidential Information marked “CONFIDENTIAL.” Such post-production
designation of Confidential Information shall not under any circumstances be
deemed a waiver, in whole or in part, of the right to assert confidentiality or of the
protections of this Protective Order, and shall not entitle the receiving party or its
attorneys to disclose such information in violation of this Protective Order.
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2. Restrictions on Confidential Information
A. Purposes: Confidential Information shall be used only for the limited purpose of
preparing for and conducting this action (including any appeals) and not for any
other purpose.
B. Recipients: Confidential Information may be disclosed only to the following:
i. Counsel of record for any party to this action, including attorneys,
paralegals, clerks, and other employees of counsel’s firms who are assisting
in this case;
ii. Consultants, investigators, experts, and their respective staffs who have
been retained by a party to provide expert or opinion testimony or to assist
in the preparation for trial or other proceedings in this case;
iii. Vendors engaged by any party to assist in copying, organizing, filing,
translating, converting, storing, retrieving or computer coding of documents
or data, or designing programs for handling documents or data, in
connection with this case;
iv. Court reporters retained to record or transcribe deposition testimony taken
in this case;
v. Any witness, although only to the extent relevant to his or her potential
testimony in this case;
vi. Persons shown on the face of a document to have authored or received it;
vii. Any person who the parties agree, in advance and in writing, may receive
such discovery materials;
viii. The Court and any mediators or arbitrators assigned to this case by the Court
or by agreement of the parties, pursuant to the terms of Paragraph 4; and
ix. Jurors.
3. Notice to Recipients of Confidential Information: Any party or representative of a party
who provides Confidential Information to a person identified in Section 2(B)(ii), (iii), (iv),
(v), (vi), (vii), or (ix) shall:
A. Notify that person that the Confidential Information is being disclosed to him or
her under the terms of the Protective Order and may not be disclosed other than as
authorized by its terms, and
B. Require that person destroy or return promptly all Confidential Information that is
disclosed to him or her.
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4. In the event that any party wishes to either file with the Court or disclose Confidential
Information in a manner not authorized by Section 2(B), the filing party shall notify the
designating party of the filing party’s intent to file/disclose Confidential Information at
least seven days in advance of filing/disclosure to provide the designating party with the
opportunity to apply to the Court for an order prohibiting or restricting the filing or
disclosure or to move the Court to file the document under seal. To the extent the parties
seek to file a document under seal, they agree to comply with W.D. Mich. LCrR 10.6.
If the filing party is permitted to file the document or other evidence containing
Confidential Information with the Court not under seal (whether such filing occurs through
the designating party’s decision to voluntarily permit the filing not under seal or pursuant
to a Court order denying sealing of the filing), the filing party agrees to file with the Court
a redacted copy of the document or other evidence, removing any and all sensitive
information (such as, but not limited to, social security numbers, personal addresses, names
or contact information of family members, confidential commercial information, etc.).
5. This Protective Order is without prejudice to the right of the parties to oppose the
admissibility of any Confidential Information produced on the grounds of lack of
relevancy, privilege, or any other legal reason.
6. Within 60 days after termination of this case by final judicial decision or otherwise, any
party that has obtained Confidential Information from another party shall either destroy
that information or return it to the party from whom it was obtained. This requirement will
not apply to Confidential Information that is contained in deposition transcripts or
pleadings or that has been filed with the Court.
7. This Protective Order does not preclude any party from seeking further relief or protective
orders from the Court, or from seeking to modify this Protective Order, as may be
appropriate under the Federal Rules of Civil Procedure.
IT IS SO ORDERED.
DATE: __________________________________
RAY KENT
U.S. Magistrate Judge
APPROVED FOR ENTRY:
/s/ Scott P. Batey (w/ permission)
Scott P. Batey (54711)
BATEY LAW FIRM, PLLC
Date: March 27, 2026
/s/ Erica L. Quigley __________
Erica L. Quigley (P84498)
MILLER JOHNSON
Date: March 27, 2026
March 30, 2026 /s/ Ray Kent
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