OSMAN ADAM ABDIRAHEEM AHMED, f/k/a RAHIM AHMED ABDIKARIN DIRIR ABDIHAKIM FARAH HASSAN FARAH MOHAMUD FARAH ABSHIR HASSAN ABSHIR MAHAMED AHMED OMAR YESHIMEBET RISKE, and IBRAHIM YUSUF Plaintiffs,
MKBS LLC, d/b/a METRO TAXI, d/b/a METRO TAXI INC., a Colorado limited liability company Defendant.
STIPULATED PROTECTIVE ORDER
MICHAEL E. HEGARTY, Magistrate Judge.
It is anticipated by Plaintiffs and Defendant that certain of Defendant's confidential business records and certain of Plaintiffs' confidential business, income and personnel records may be produced in discovery in this matter. The parties agree that such confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, must be protected from further disclosure or dissemination. Pursuant to Federal Rule of Civil Procedure 26(c), the Court finds good cause for entry of this Stipulated Proposed Protective Order to provide such protection according to the terms and conditions below.
1. To expedite the flow of discovery material and the litigation of this case, facilitate the prompt resolution of disputes over confidentiality, and adequately protect material entitled to be kept confidential, it is, by agreement of the Parties, STIPULATED and ORDERED that:
2. 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 and the Pilot Project Regarding Initial Discovery Protocols for Employment Cases Alleging Adverse Action.
3. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL information") shall not, without the consent of the party producing it and the consent of the party claiming confidentiality (if that party is different from the producing party) or further Order of the Court, be disclosed or made available in any way to any person except that such information may be disclosed to:
(a) attorneys who are actively working on this case;
(b) persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties, including designated representatives for Defendant;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial, or other proceedings in this case;
(e) the Court in this case and its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this case;
(g) deponents, witnesses, or potential witnesses; and
(h) other persons by written agreement of the parties.
4. As used in this Protective Order, "document" is defined as provided in Federal Rule of Civil P. 34(a)(1)(a). A draft or non-identical copy is a separate ...