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Kerber v. Qwest Pension Plan

February 9, 2006

EDWARD J. KERBER, NELSON B. PHELPS, INDIVIDUALLY, AND AS REPRESENTATIVES OF PLAN PARTICIPANTS AND PLAN BENEFICIARIES OF THE QWEST PENSION PLAN, PLAINTIFFS,
v.
QWEST PENSION PLAN, QWEST EMPLOYEES BENEFIT COMMITTEE, QWEST PENSION PLAN DESIGN COMMITTEE, QWEST COMMUNICATIONS INTERNATIONAL, INC., DEFENDANTS.



The opinion of the court was delivered by: Boyd N. Boland United States Magistrate Judge

STIPULATED PROTECTIVE ORDER

This Order is entered pursuant to F.R.C.P. 26(c) and by the amended stipulation and agreement of the parties hereto, as acknowledged by the signatures of their respective counsel below.

IT IS HEREBY ORDERED:

1. For purposes of this Order, the following terms shall have the following meanings:

a. "Documents" shall have that definition as described in Fed. R. Civ. P. 34 and shall include (1) all written, printed, recorded, taped, digitally encoded, graphic, photographic, or other information whatsoever; and (2) all copies, reproductions, summaries, translations and drafts thereof, including all copies bearing notations and marks not found on the original.

b. "Discovery material" shall mean (1) all documents produced in this action by any party or nonparty, whether pursuant to formal discovery or by agreement; (2) transcripts of any depositions taken in this action; (3) interrogatory answers served in this action; and (4) requests to admit and responses thereto served in this action.

c. "Disclose" shall mean to show, give, make available, reproduce, excerpt, summarize or otherwise reveal the contents of any documents or discovery materials or any part thereof.

d. "Producing party" shall mean any person (including third parties not named in this action), who produces Discovery Material in this case.

e. "Confidential information" shall mean information which is confidential or proprietary in nature, such as, but not limited to, trade secrets, research and development, customer lists or other commercial information that has been kept confidential by the producing party, as well as any information that implicates a common law or statutory privacy interest such as personal identifying information or any other information that is otherwise entitled to protection under Fed.R.Civ.P. 26(c)(7).

2. Any producing party who believes that any discovery material produced in this action contains or discloses confidential information must have such discovery material reviewed by a lawyer. If said lawyer, based on a good faith belief that the information sought to be protected is confidential or otherwise entitled to protection pursuant to Fed. R. Civ. Proce. 26(c)(7), deems the materials to be or contain confidential information, the producing party may designate and mark any such material as "confidential".

3. Any discovery material, which is designated "confidential" by a producing party ("confidential discovery material"), shall be treated as confidential in accordance with the terms of this Order.

4. All confidential discovery material shall be used solely for the prosecution or defense of the above-titled action.

5. Any producing party designating any document produced in this action as confidential, in accordance with paragraph 3 above, may do so by stamping "Confidential" in a size and location which make the designation readily apparent on every page of the document that is designated as confidential.

6. Any party designating any deposition testimony in this action as "confidential", in accordance with paragraph 3 above, may do so by advising the reporter and opposing counsel of its desire to designate the entire transcript, or any portion thereof, as "confidential."

a. The designation may be made during the deposition. The designation must be made no later than the time allowed for signature of the transcript, or when signature is waived, within the (10) days after receipt of the transcript by designating party.

b. The reporter shall mark the face of the designated transcript, or the designated portions of the transcript, accordingly. If less than an entire transcript is designated as confidential, those portions so designated shall be printed on separate, appropriately marked pages and separately bound.

c. If any designated deposition is to be filed, the designating party, or its reporter, shall file the transcript under seal with the Court, and simultaneously file a Motion to Seal with the Court seeking protection in accordance with the requirements of D.C.Colo.LCivR 7.2 and 7.3.

d. Until the time allowed for designation has expired, all depositions shall be deemed confidential in their entirety, but thereafter only if and to the extent a party has ...


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