UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

KATE MILLS, an 

Individual, 

 Plaintiff Case No. 2:08-cv-14291-PJD-VMM 

vs. Hon. Patrick J. Duggan 

 

WALTER RODABAUGH, in an official 

and unofficial capacity, an Individual, 

JEFFREY BROOKS, in an official and 

unofficial capacity, an Individual, and 

COUNTY OF LAPEER, a Michigan 

municipal entity. 

 Defendants. 

-ANDANDREW MILLS, an 

Individual, 

 Plaintiff Case No. 2:09-10921 PJD-VMM 

vs. Hon. Patrick J. Duggan 

WALTER RODABAUGH, in an official 

and unofficial capacity, an Individual, 

JEFFREY BROOKS, in an official and 

unofficial capacity, an Individual, and 

COUNTY OF LAPEER, a Michigan 

municipal entity. 

 Defendants. 

SEIFMAN & GUZALL, P.C. 

BY: Kevin J. Watts (P64852) 

 Barry A. Seifman (P20197) 

Attorneys for Plaintiff 

30665 Northwestern Hwy., Ste. 255 

Farmington Hills, Michigan 48334 

248 538-0711 

Fax 248-932-1112 

kevin.watts@thelawadvocate.com 

JOHNSON, ROSATI, LaBARGE, 

ASELTYNE & FIELD, P.C. 

BY: S. Randall Field (P31841) 

Attorney for Defendants 

34405 W. Twelve Mile Road, Suite 200 

Farmington Hills, Michigan 48331-5627 

248 489-4100 

Fax 248-489-4100 

rfield@jrlaf.com 

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STIPULATED PROTECTIVE ORDER

At a session of said Court held in the City of Detroit, 

County of Wayne, State of Michigan on 

 September 21, 2009. 

 PRESENT: THE HONORABLE PATRICK DUGGAN, U.S. DISTRICT COURT JUDGE 

This matter having come before the Court upon Stipulation of the parties for a Protective 

Order, the Court directs that the documents listed herein presented by the County of Lapeer 

Defendants in this litigation, either voluntarily, pursuant to Discovery request, or pursuant to Court 

Order shall be subject to this Protective Order. The documents shall include the Lapeer County 

Sheriff’s Deputy Jeff Brooks’ personnel file, which shall be provided to Plaintiffs’ 

counsel of record, subject to the following conditions:

1. The documents are limited to the use in the consolidated case of Kate Mills and 

Andrew Mills v County of Lapeer, et al, Case No. 2:08-cv-14291-PJD-VMM and 2:09-cv-10921-PJDVMM, currently pending in the United States District Court, Eastern District of Michigan, Southern 

Division, before the Honorable Patrick Duggan. 

2. The documents maybe reviewed only by counsel of record, counsel of record's 

support personnel, the Plaintiffs, and such expert witnesses and/or consultants as counsel of record 

deems necessary for purposes of this litigation, as well as any persons to whom the documents 

may be presented for evaluation and/or evidentiary purposes such as mediators, case evaluators, 

facilitators, judge, or jury, subject to the provisions of paragraphs 3 and 4 below. 

3. Any person to whom the documents are shown must be provided with a copy of this 

Stipulated Protective Order and must agree to abide by the terms thereof. 

4. No person, including counsel of record, counsel of record's support personnel, the 

Plaintiffs, and/or any expert witness and/or consultants retained by any party in this matter, may 

retain a copy of the documents; upon written request from Defendants’ counsel, a record of a 

2:08-cv-14291-PJD-VMM Doc # 26 Filed 09/21/09 Pg 2 of 3 Pg ID 127
number of copies made, the name of the persons to whom copies have been given, and all copies 

of the documents shall be returned to Defendants' counsel, S. Randall Field, upon settlement of this 

matter, or upon entry of a final judgment after all appeals have been exhausted. 

5. Neither the actual documents, nor the information contained therein, may be 

disclosed to any other person or entity not identified in this Stipulated Protective Order, nor used 

by any persons for any purpose other than direct use in this litigation. 

6. The Plaintiff shall further provide the defense counsel at the time of re-delivery of 

the documents, an Affidavit stating that Plaintiff has complied with the provisions of this Stipulated 

Protective Order. 

7. The parties reserve the right to add additional documents to come within 

this protective order should it become necessary during the course of discovery.

 IT IS HEREBY ORDERED. 

 s/Patrick J. Duggan

 Patrick J. Duggan 

 United States District Judge 

Dated: September 21, 2009 

I hereby certify that a copy of the foregoing document was served upon counsel of record on 

September 21, 2009 ,by electronic and/or ordinary mail. 

 s/Marilyn Orem

 Case Manager 

Approved as to form and content: 

JOHNSON, ROSATI, LaBARGE, 

ASELTYNE & FIELD, P.C. 

s/S. Randall Field s/Kevin J. Watts

Attorney for Defendants Kevin J. Watts (P64852) 

34405 W. Twelve Mile Road, Suite 200 30665 Northwestern Hwy., Ste 255 

Farmington Hills, MI 48331-5627 Farmington Hills, Michigan 48334 

cyoung@jrlaf.com 248-538-0711 

(248) 489-4100 

(P 31841) 

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