UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

MANUFACTURING TECHNOLOGY 

SOLUTIONS, LLC, an Indiana limited 

liability company, 

 Plaintiff/Counter-Defendant, Case No. 09-12499 

 Hon. Patrick J. Duggan 

v. 

DIVERSIFIED MACHINE, INC., 

a Delaware corporation, 

 Defendant/Counter-Plaintiff. 

__________________________________/ 

Leif K. Anderson (P53305) Russell S. Linden (P34863) 

Neuman Anderson PC Honigman Miller Schwartz and Cohn LLP 

29100 Northwestern Hwy., Ste. 260 660 Woodward Ave., 2290 First National Bldg. 

Southfield, MI 48034 Detroit, MI 48226 

(248) 352-5522 (313) 465-7466 

landerson@neumananderson.com rlinden@honigman.com 

STIPULATED PROTECTIVE ORDER

 At a session of said Court held in 

the Theodore S. Levin United States 

Courthouse, Detroit, Michigan, 

 on: December 10, 2009 

 BEFORE: HON. PATRICK J. DUGGAN 

 United States District Court Judge 

 The parties having stipulated to entry of this order through their respective counsel, and the 

Court otherwise being fully advised in the premises; 

 IT IS HEREBY ORDERED that: 

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 1. Certain documents to be produced during this litigation are confidential or contain 

confidential information and shall be treated as follows: 

 a. Any documents to be produced which Plaintiff and/or Defendant believe to 

contain confidential information shall be designated as "Protected" or "Confidential" (hereinafter 

"Protected Document"). Such designation shall be made at the time the documents are made 

available to opposing counsel for inspection or at any time thereafter. The parties shall make a 

good faith effort only to designate documents as "Protected Documents" as they believe require 

protection and confidentiality. Should any party disagree with the designation of documents as 

Protected or Confidential, this Court shall review the document(s) in camera and determine 

whether protection pursuant to this Order is required by either party. A document designated as a 

Protected Document shall remain protected pursuant to this Order until the Court rules that any 

such document(s) is/are not to be treated as “Confidential.” In addition, any document which a 

party designates as Protected or Confidential, which is not disputed by the other party, shall be 

deemed a Protected Document. 

 b. Any Protected Document shall be used solely for the purposes of this 

litigation. Specifically, and without limitation, any Protected Document shall not be used for any 

business or competitive purpose. Disclosure of any Protected Document, or information contained 

therein, shall not be made to anyone other than (i) counsel for Plaintiff and respective counsel for 

Defendant (including associates, legal assistants or clerical personnel who are directly employed by 

and assisting counsel), any retained expert witness(es), stenographic reporters taking testimony in 

connection with this litigation, and the parties; or (ii) this Court, its duly appointed officers, and 

case evaluation panel members. No Protected Document, nor any information contained therein, 

shall be disclosed (except to the to the parties’ respective counsel, the Court, its duly appointed 

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officers, and mediation panel members) unless that individual has signed a Confidentiality 

Agreement (such as is attached as Exhibit 1) pursuant to which the individual acknowledges having 

reviewed a copy of this Order and agreeing to be bound by this Order. Plaintiff and Defendant 

shall retain all signed copies of the Confidentiality Agreement and shall, upon another counsel's or 

the Court's request, provide copies to opposing counsel or to the Court. 

 (c) No copies, transcriptions or summaries of the Protected Documents, or any 

information contained therein, shall be made except to the extent necessary to prepare this case for 

trial. 

 (d) Transcripts or summaries of the Protected Documents, or any information 

contained therein, shall be kept separate from other transcribed testimony summaries and shall be 

clearly marked as protected. 

 (e) Upon final resolution of this litigation, counsel shall return all copies and all 

other forms of the Protected Documents upon written request of the producing party, except as 

necessary for counsel to maintain a complete file in this matter. 

 2. The entry of this Order does not constitute an admission, agreement, finding or 

ruling that any document or information is subject to discovery or is admissible as evidence in this 

case. Designation of any information as subject to this Order shall have no meaning or effect 

whatsoever with respect to the substantive issues in this proceeding for the claims or defenses of 

any party hereto. 

 3. The provisions of this Protective Order shall continue in effect and shall survive the 

final resolution in this litigation. Because the unauthorized disclosure of the Protected Documents 

will cause irreparable harm, the terms of this Protective Order may be enforced by injunction. 

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 IT IS SO ORDERED. 

 s/Patrick J. Duggan

 Patrick J. Duggan 

 United States District Judge 

Dated: December 10, 2009 

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

December 10, 2009, by electronic and/or ordinary mail. 

 s/Marilyn Orem

 Case Manager 

Stipulated as to Entry: 

LITIGATION ASSOCIATES, PLLC HONIGMAN MILLER SCHWARTZ 

 AND COHN LLP 

Attorneys for Plaintiff/Counter-Defendant Attorneys for Defendant-Counter Plaintiff 

By: /s/Leif K. Anderson (w/permission) By: /s/Russell S. Linden 

 Leif K. Anderson (P53305) Russell S. Linden (P34863) 

 Neuman Anderson PC 660 Woodward Avenue 

 29100 Northwestern Hwy., Ste. 260 2290 First National Building 

 Southfield, MI 48034 Detroit, Michigan 48226 

 (248) 352-5522 (313) 465-7466 

Div. Machine.3962709 

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