Lopez v. Social Security Administration - Document 6

FieldTurf USA, Incorporated et al v. AirSide Turf, Incorporated et al Doc. 6 Case 2:07-cv-11306-AC-SDP Document 6 Filed 04/05/2007 Page 1 of 3 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION FIELDTURF USA, INC., a Florida corporation, and FIELDTURF TARKETT INC., a Canadian company, Plaintiffs, vs AIRSIDE TURF, INC., a Michigan corporation, and JOSEPH DOBSON, an individual Defendants. _____________________________________________________________________________ THE WATSON IP GROUP, PLC Jovan N. Jovanovic (P66644) Attorney for Plaintiffs 3133 Highland Drive, Suite 200 Hudsonville, MI 49426 (616)855-1521 HONIGMAN MILLER SCHWARTZ AND COHN LLP William D. Sargent (P38143) Henry J. Andries, Jr. (P53669) Robert J. Muchnick (P62369) Attorneys for Defendants 2290 First National Building Detroit, MI 48226 (313) 465-7000 Civil Action No. 07-11306 Hon. Avern Cohn FACTOR & LAKE, LTD. Jody L. Factor (Not Admitted in MI) Nicholas S. Lee (Not Admitted in MI) Attorneys for Plaintiffs 1327 W. Washington Blvd. Suite 5G/H Chicago, Ill 60607 (312) 226-1818 _____________________________________________________________________________ STIPULATED ORDER This matter having come before the Court on FieldTurf's1 Ex Parte Motion for Temporary Restraining Order and Preservation of Documents, Software and Things and Motion for Expedited and Early Discovery, the Court having conducted a conference call with counsel 1 Plaintiffs FieldTurf USA, Inc. and FieldTurf Tarkett, Inc. are collectively referred to herein as "FieldTurf." Dockets.Justia.com  Case 2:07-cv-11306-AC-SDP Document 6 Filed 04/05/2007 Page 2 of 3 on Friday, March 30, 2007, the Court having declined on March 30 to issue temporary injunctive relief, the Court having scheduled a hearing concerning injunctive relief for Friday, April 6, 2007, the Court having permitted expedited discovery and preservation of documents. Pursuant to stipulation of the parties: IT IS HEREBY ORDERED THAT the April 6, 2007 hearing scheduled by the Court concerning injunctive relief is vacated. IT IS HEREBY ORDERED THAT Dobson shall not use or disclose any documents and records, including physical product samples (e.g. synthetic turf samples), that he obtained from FieldTurf during his employment with FieldTurf, whether in original, copied, computerized, or handwritten form. IT IS HEREBY ORDERED THAT Plaintiffs and Defendants shall not purge or destroy, and shall preserve, all discoverable business records, documents and things, in their possession, custody and control, whether in original, copied, computerized, or handwritten form. IT IS HEREBY FURTHER ORDERED that the parties may conduct limited expedited discovery as follows: within twenty (20) days of service, the parties shall respond to requests for production of documents and interrogatories, and the parties may begin taking depositions thereafter. The limited discovery shall be directed to injunctive relief issues. In the event that the parties cannot resolve an issue pertaining to the scope of any discovery request, the parties may request the Court to conduct a telephonic discovery conference to resolve the issue before filing any moving documents. IT IS HEREBY ORDERED THAT neither the parties stipulation, nor the entry of this Order, shall: (i) be construed as an admission or agreement that FieldTurf is or is not entitled to injunctive relief; (ii) constitute an admission, agreement, finding or ruling that any document or 2  Case 2:07-cv-11306-AC-SDP Document 6 Filed 04/05/2007 Page 3 of 3 information is or is not subject to discovery, or is or is not admissible as evidence in this case; (iii) diminish, eliminate, or otherwise affect any claim or position that any party may assert, or has asserted, in this case, and shall have no meaning or effect whatsoever with respect to the substantive issues in this litigation and with respect to the claims or defenses of any party hereto; and (iv) shall not be construed as an admission or agreement that any information and/or specific document is or is not confidential, proprietary and/or or a trade secret. IT IS HEREBY ORDERED THAT this Stipulated Order may be terminated, dissolved or modified by stipulation of the parties or by further Order of this Court. Dated: April 5, 2007 s/Avern Cohn U.S. DISTRICT COURT JUDGE STIPULATED AND APPROVED FOR ENTRY: s/Jovan N. Jovanovic (with permission) Jovan N. Jovanovic (P66644) Attorney for Plaintiffs Dated: April 4, 2007 DETROIT.2570766.2 STIPULATED AND APPROVED FOR ENTRY: s/Henry J. Andries Henry J. Andries, Jr. (P53669) Attorney for Defendants Dated: April 4, 2007 3