United States District Court, D. Colorado
COLORADO CROSS-DISABILITY COALITION, a Colorado non-profit organization, Plaintiff,
REGIONAL TRANSPORTATION DISTRICT, a political subdivision of the State of Colorado, Defendant.
STIPULATED PROTECTIVE ORDER (Docket No. 13-1)
MICHAEL J. WATANABE, Magistrate Judge.
The parties, by and through their respective counsel, hereby agree to the following Stipulated Protective Order and request that it be entered as an Order of the Court.
Upon a showing of good cause in support of the entry of a protective order to protect the disclosure and discovery of confidential information 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. Information designated "CONFIDENTIAL" may be information in which a party has a statutory, regulatory, or common law right of privacy or protection against dissemination or disclosure, specifically including but not limited to medical information, passenger information, as well as personnel information. Nothing in this order is intended to waive any argument that information designated as confidential, including but not limited to medical or records of disability, is not confidential information nor prevent a party from taking a position or advancing an argument that confidentiality of any record has been waived by placing that information into issue by claims or defenses raised in this case.
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 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 including insurance and/or selfinsurance representatives for the entity parties or parties sued in their official capacity;
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 and its employees ("Court Personnel");
f. stenographic reporters who are engaged in proceedings necessarily incident to the ...