UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

SCOTT TRUJILLO, 

 Plaintiff, Case No. 2:09-CV-13751 

 Hon. Marianne O. Battani 

vs. 

HENNIGES AUTOMOTIVE SEALING 

SYSTEMS NORTH AMERICA, INC., 

a foreign corporation sometimes doing 

business as “GDX Automotive” and formerly 

known as “GDX North America Inc.”, 

 Defendant. 

_____________________________________________________________________ 

ALSPECTOR, SOSIN & NOVECK, PLLC 

By: ROBERT M. SOSIN P35414 

Attorneys for Plaintiff 

30100 Telegraph Road, Suite 302 Bingham 

Farms, MI 48025-4517 

(248)642-3200 

Catherine A. Tracey (P63161) 

Thomas R. Wurst (P30177) 

MILLER JOHNSON 

Attorneys for Defendant 

250 Monroe Avenue, N.W., Suite 800 

Grand Rapids, MI 49503 

(616) 831-1792 

_____________________________________________________________________ 

CONFIDENTIALITY AGREEMENT

AND STIPULATED PROTECTIVE ORDER

Preamble

 The parties anticipate that in the course of discovery Defendant Henniges 

Automotive Sealing Systems North America, Inc. (“Henniges”) will produce to Plaintiff Scott 

Trujillo (“Trujillo”) or his counsel documents, testimony, and other information that Henniges 

considers to be confidential, including but not limited to information concerning Henniges’ 

business, finances, employees and employee compensation. The documents and testimony 

containing this information are subject to the protection of the Court under Federal Rule of Civil 
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Procedure 26(c). The parties agree that justice requires that reasonable measures be established 

to protect the confidentiality of this information, as set forth below. 

Stipulation

 The parties agree as follows, and stipulate to the Court’s entry of an Order 

containing the following terms and conditions: 

 1. For purposes of this Stipulated Protective Order: “Henniges Business 

Information” means any information related to Henniges’ business operations, finances, 

employees and employee compensation, including but not limited to any written or electronic 

documents or other materials containing such information and any copies or reproductions 

thereof, where such information either (i) is not generally available to the public, or (ii) has been 

marked “Confidential” or designated as “Confidential” by Henniges prior to its production by 

Henniges to Trujillo or his counsel. 

 2. Henniges Business Information will be subject to the following 

restrictions: 

 a. Neither Trujillo nor his counsel, nor any other person acting in 

Trujillo’s behalf, shall disclose any Henniges Business Information to any other person, except 

(i) to persons regularly employed in the law offices of Trujillo’s counsel as necessary for those 

persons to render services on Trujillo’s behalf in connection with this case; or (ii) to bona fide 

experts consulted by Trujillo’s counsel in connection with this case. Each person to whom 

Henniges Business Information is provided shall be provided with a copy of this Agreement and 

Order. No person to whom disclosure is made shall divulge any Henniges Business Information 

to any other person. Any person having actual knowledge of this Order is bound to the full 

extent of its terms. 
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 b. In the event that Trujillo wishes to file any Henniges Business 

Information with the Court or to disclose Henniges Business Information in a manner not 

authorized by paragraph 2.a., Trujillo will advise counsel for Henniges of the intended filing or 

disclosure by written notice delivered at least seven days prior to the date of the intended filing 

or disclosure. If Henniges objects to the filing or disclosure, Henniges will notify Plaintiff’s 

counsel in writing of its objection and apply to the Court for an order prohibiting or restricting 

the filing or disclosure. No disclosure shall be made until the Court rules upon the application 

for protection. 

 3. Documents, deposition transcripts, reports, and other discovery material 

containing Henniges Business Information shall be used only for purposes directly related to the 

prosecution or defense of claims in this action, and not for any other purpose. 

 4. At the conclusion of all proceedings in this litigation, all Henniges 

Business Information in the possession of Trujillo or his counsel, experts or other representatives 

shall be destroyed or returned to Henniges. The termination of proceedings in this litigation shall 

not relieve any person from the obligations of this Agreement and Order. The Court may retain 

jurisdiction after the final disposition of this litigation for the purposes of any application to 

modify or enforce the provisions of this Agreement and Order. 

_/s/ Robert M. Sosin (w/ permission)______ _/s/ Catherine A. Tracey___________

Robert M. Sosin (P35414) 

ALSPECTOR, SOSIN & NOVECK, PLLC 

Attorneys for Plaintiff 

Catherine A. Tracey (P63161) 

MILLER JOHNSON 

Attorneys for Defendant 
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ORDER

 Based on the Stipulation of the parties set forth above, 

 

IT IS SO ORDERED. 

Date: June 10, 2010 s/Marianne O. Battani

 Hon. Marianne O. Battani 

 U.S. District Court Court Judge 

 

GR_DOCS 1609177v1 20132.005