Opinion
Case No. 11-cv-15508
05-11-2012
GEORGIA M. BROWN, Plaintiff, v. VHS OF MICHIGAN, INC., d/b/a/ DETROIT MEDICAL CENTER, A Delaware For Profit Corporation, Defendant.
CHRISTOPHER W. QUINN, II (P69483) Attorney for Plaintiff THE ALLEN LAW GROUP P.C. GEORGE D. MESRITZ (P27866) Attorneys for Defendant DETROIT MEDICAL CENTER LEGAL AFFAIRS CHARLES N. RAIMI (P29746) Co-Counsel for Defendant
Hon.
Magistrate Judge Mona K. Majzoub
CHRISTOPHER W. QUINN, II (P69483)
Attorney for Plaintiff
THE ALLEN LAW GROUP P.C.
GEORGE D. MESRITZ (P27866)
Attorneys for Defendant
DETROIT MEDICAL CENTER
LEGAL AFFAIRS
CHARLES N. RAIMI (P29746)
Co-Counsel for Defendant
STIPULATED PROTECTIVE ORDER AS TO DEFENDANT'S PRODUCTION OF
DOCUMENTS REGARDING CURRENT AND FORMER EMPLOYEES
STIPULATED PROTECTIVE ORDER AS TO DEFENDANT'S PRODUCTION OF
DOCUMENTS REGARDING CURRENT AND FORMER EMPLOYEES
At a session of said Court held on
PRESENT: ROBERT H. CLELAND
HAVING BEEN DULY ADVISED by the parties that they have agreed to entry of this Stipulated Protective Order As To Defendant's Production of Documents Regarding Current and Former Employees; and otherwise being duly advised in the premises; and, therefore,
IT IS HEREBY ORDERED THAT Plaintiff Georgia M. Brown, and her attorney, shall use the documents produced by Defendant, listed below, only for purposes of this litigation, and shall not use the documents for any other purpose or proceeding, and shall not give to any person (other than to this Court or to representatives of this Court, or to Defendant's attorneys, or to Plaintiff's experts), the documents, or copies thereof, or disclose to any person (other than to this Court or to representatives of this Court, or to Defendant's attorneys, or Plaintiff's experts), the information contained in said documents -- unless first obtaining the written permission of this Court or Defendant's attorneys. The documents to which this Protective Order applies are as follows:
1. The resumes of Patricia Wilkerson-Uddyback, M.D; Dajuan Smith; Barbara A. Washington; Michele E. Berry; Daniel P. Keehner; and Arnettie Morton;
2. The resumes of all other current and former employees with respect to whom resumes are produced during this litigation; and
3. All documents which contain information regarding the qualifications, job and education histories, and other personal information regarding Defendant's current and former employees.
IT IS HEREBY FURTHER ORDERED THAT, after this case is concluded and all appeal rights exhausted, Plaintiff and her attorney shall return all of the listed documents, and all copies thereof, within ten (10) days of a written request by Defendant or its attorneys.
Robert H. Cleland
District Court Judge
APPROVED AS TO FORM:
CHRISTOPHER W. QUINN, II (P69483)
Attorney for Plaintiff
THE ALLEN LAW GROUP P.C.
GEORGE D. MESRITZ (P27866)
Attorneys for Defendant