The opinion of the court was delivered by: Boyd N. Boland United States Magistrate Judge
Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which may annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.
2. As used in this Protective Order, "document" is defined as provided in FED. R. CIV. P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. The parties may designate as "CONFIDENTIAL" information that is confidential and that implicates the privacy interests of (a) current or former School District employees, including the plaintiff and (b) current or former School District students, and may include, without limitation, personnel records, student records, and personal information related to the plaintiff (e.g. financial and medical records). CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case and as stated in this Protective Order.
4. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL information") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:
(a) attorneys working on this case;
(b) persons employed or associated with the attorneys working on the case;
(c) the parties, including designated representatives for the defendant;
(d) expert witnesses and consultants retained in connection with this proceeding;
(e) the Court and its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
(g) deponents, witnesses, or potential witnesses; and
(h) other persons by written agreement of ...