UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

TARAS P. NYKORIAK, 

Case No. 2:08-cv-15024

Plaintiff, Hon. John Corbet O’Meara

v. Mag. Judge R. Steven Whalen

EXPERIAN, 

Defendant.

Taras P. Nykoriak (In Pro Se) Sidney L. Frank (P13637)

12147 McDougall Tamara E. Fraser (P51997)

Hamtramck, Michigan 48212 Frank, Haron, Weiner and Navarro 

(248) 990-3574 Attorneys for Defendant

5435 Corporate Drive, Suite 225

Troy, Michigan 48098

(248) 952-0400

STIPULATED PROTECTIVE ORDER

IT IS HEREBY STIPULATED by and between Plaintiff Taras Nykoriak (“Plaintiff”) acting

in pro per and Defendant Experian Information Solutions, Inc. (“Experian”), through its attorney

of record, as follows:

WHEREAS, documents and information have been and may be sought, produced or

exhibited by and between the parties to this action relating to trade secrets, confidential research,

development, technology or other proprietary information belonging to the defendants and/or

personal income, credit and other confidential information of Plaintiff.

THEREFORE, an Order of this Court protecting such confidential information shall be and

hereby is made by this Court on the following terms:

1. This Order shall govern the use, handling and disclosure of all documents, testimony

or information produced or given in this action which are designated to be subject to this Order in

accordance with the terms hereof.

2. Any party or non-party producing or filing documents or other materials in this action

Case 5:08-cv-15024-JCO-RSW Document 8 Filed 02/27/09 Page 1 of 4
2

may designate such materials and the information contained therein subject to this Order by typing

or stamping on the front of the document, or on the portion(s) of the document for which

confidential treatment is designated, "Confidential."

3. To the extent any motions, briefs, pleadings, deposition transcripts, or other papers

to be filed with the Court incorporate documents or information subject to this Order, the party filing

such papers shall designate such materials, or portions thereof, as "Confidential," and shall file them

with the clerk under seal; provided, however, that a copy of such filing having the confidential

information deleted therefrom may be made part of the public record.

4. All documents, transcripts, or other materials subject to this Order, and all

information derived therefrom (including, but not limited to, all testimony, deposition, or otherwise,

that refers, reflects or otherwise discusses any information designated Confidential hereunder), shall

not be used, directly or indirectly, by any person, including the other defendants, for any business,

commercial or competitive purposes or for any purpose whatsoever other than solely for the

preparation and trial of this action in accordance with the provisions of this Order.

5. Except with the prior written consent of the individual or entity asserting confidential

treatment, or pursuant to prior Order after notice, any document, transcript or pleading given

confidential treatment under this Order, and any information contained in, or derived from any such

materials (including but not limited to, all deposition testimony that refers, reflects or otherwise

discusses any information designated confidential hereunder) may not be disclosed other than in

accordance with this Order and may not be disclosed to any person other than: (a) the Court and its

officers; (b) parties to this litigation; (c) counsel for the parties, whether retained counselor in-house

counsel and employees of counsel assigned to assist such counsel in the preparation of this litigation;

(d) fact witnesses subject to a proffer to the Court or a stipulation of the parties that such witnesses

need to know such information; and (e) present or former employees of the producing party in

Case 5:08-cv-15024-JCO-RSW Document 8 Filed 02/27/09 Page 2 of 4
3

connection with their depositions in this action (provided that no former employees shall be shown

documents prepared after the date of his or her departure).

6. All persons receiving any or all documents produced pursuant to this Order shall be

advised of their confidential nature. All persons to whom confidential information and/or documents

are disclosed are hereby enjoined from disclosing same to any other person except as provided

herein, and are further enjoined from using same except in the preparation for and trial of the

above-captioned action between the named parties thereto. No person receiving or reviewing such

confidential documents, information or transcript shall disseminate or disclose them to any person

other than those described above in Paragraph 5 and for the purposes specified, and in no event shall

such person make any other use of such document or transcript.

7. Nothing in this Order shall prevent a party from using at trial any information or

materials designated "Confidential."

8. This Order has been agreed to by the parties to facilitate discovery and the production

of relevant evidence in this action. Neither the entry of this Order, nor the designation of any

information, document, or the like as "Confidential," nor the failure to make such designation, shall

constitute evidence with respect to any issue in this action.

9. Within sixty (60) days after the final termination of this litigation, all documents,

transcripts, or other materials afforded confidential treatment pursuant to this Order, including any

extracts, summaries or compilations taken therefrom, but excluding any materials which in the good

faith judgment of counsel are work product materials, shall be returned to the individual or entity

having produced or furnished same or be destroyed.

10. Nothing herein shall affect or restrict the rights of any party with respect to its own

documents or to the information obtained or developed independently of documents, transcripts and

materials afforded confidential treatment pursuant to this Order.

Case 5:08-cv-15024-JCO-RSW Document 8 Filed 02/27/09 Page 3 of 4
4

Dated: February ____, 2009 s/with consent of Taras Nykoriak 

Taras Nykoriak (In Pro Per)

Dated: February____, 2009 s/Tamara E. Fraser 

 Tamara E. Fraser (P51997)

Attorney for Defendant Experian Information 

 Solutions, Inc.

248-952-0400

SO ORDERED.

Date: February 27, 2009 s/John Corbett O’Meara

United States District Judge

Case 5:08-cv-15024-JCO-RSW Document 8 Filed 02/27/09 Page 4 of 4