UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

BRAINTECH, INC., 

Plaintiff/Counter-Defendant, 

v. Case No: 09-10454 

Honorable Victoria A. Roberts 

ADIL SHAFI, 

Defendant/Counter-Plaintiff/ 

Third-Party Plaintiff, 

v. 

FREDERICK WEIDINGER AND 

BRAINTECH, INC., 

Third-Party Defendant/Counter-Defendant. 

 

STIPULATED PROTECTIVE ORDER

 The parties, by and through counsel, agree and stipulate that information regarding or 

relating to Braintech, Inc.’s insurance coverage, that will be produced pursuant to the Court’s 

June 15, 2010 Order, is confidential and shall be subject to this Protective Order. 

 The insurance information to be disclosed is confidential and will be used for purposes of 

this litigation only. The confidential insurance information will be disclosed only to Qualified 

Persons. Qualified Persons are defined as: 

1. Legal professionals and staff to whom disclosure is necessary in order to conduct this 

litigation, including attorneys of record in this proceeding, their secretaries, 

paralegals, law clerks and support staff. 

2. The named parties in this proceeding and, if applicable, their respective officers, 

directors, attorneys and insurers. 

Case 2:09-cv-10454-VAR-VMM Document 68 Filed 11/22/10 Page 1 of 3
2 

Qualified Persons permitted to review confidential insurance information under this 

Order will, before obtaining access to the confidential insurance information, be shown a copy of 

this Order and agree in writing to be bound by its terms by signing this Order. Counsel for the 

party wishing to disclose such material must retain the signed Order and produce it to counsel for 

Braintech on request. 

The terms of this Order shall continue in effect during and after the conclusion of the 

action. Within 20 days following entry of a final, non-appealable order disposing of the action, 

parties in possession of the confidential insurance information covered by this Order shall return 

all such confidential insurance information, including copies, to Braintech, Inc.’s counsel of 

record. 

If any party to this action receives a subpoena or other formal demand from any source, 

whether related to another cause of action, proceeding, investigation, or otherwise for the 

production or disclosure of the confidential insurance information, that party must provide 

written notice of the subpoena or demand to counsel for Braintech at least fourteen (14) days 

before the party’s required response to the subpoena or demand and that party must not interfere 

with any action that Braintech may elect to take to protect the confidentiality of the confidential 

insurance information. If, however, a response by a party to this action to such a subpoena or 

demand is required in less than fourteen (14) days, that party must provide Braintech with 

immediate notice in writing to its counsel Anne Widlak or Susan Koval, by fax [(313) 567-5928] 

and by telephone [(313) 567-5921], to provide Braintech with as much time as possible to take 

action to protect the confidentiality of the confidential insurance information, and the parties 

must not interfere with any action Braintech may elect to take to protect the confidentiality of the 

confidential insurance information. 

Case 2:09-cv-10454-VAR-VMM Document 68 Filed 11/22/10 Page 2 of 3
3 

IT IS SO ORDERED. 

 S/Victoria A. Roberts

 UNITED STATES DISTRICT JUDGE 

Dated: 11/22/2010 

Agreed as to form and substance: 

/s/ with consent of James P. Murphy /s/ Susan D. Koval 

James P. Murphy (P31997) Anne Widlak (P35763) 

Attorney for Shafi Susan D. Koval (P59297) 

Berry Moorman PC Attorneys for Defendant Braintech, Inc. 

 535 Griswold Street, Ste. 1900 Nemeth Burwell, P.C. 

The Buhl Building 200 Talon Centre Drive, Ste. 200 

Detroit, MI 48226 Detroit, MI 48207 

/s/with consent of Geoffrey Greeves 

Geoffrey Greeves 

Attorney for Defendant Weidinger 

Pillsbury Winthrop Shaw Pittman LLP 

2300 N Street, N.W. 

Washington, DC 20037-1122 

Case 2:09-cv-10454-VAR-VMM Document 68 Filed 11/22/10 Page 3 of 3