United States District Court, D. Colorado
BOYD N. BOLAND, Magistrate Judge.
Pursuant to the Joint Stipulated Motion for Protective Order filed by the parties, the Court hereby Orders as follows:
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 that is disclosed in this matter pursuant to (a) the disclosure or discovery duties created by the Rules of Civil Procedurep (b) agreement of the partiesp and/or (c) orders of the Court.
2. As used in this Protective Order, "document" is defined as provided in Federal Rules of Civil Procedure. A draft or nonidentical copy is a separate document within the meaning of this term.
3. One who provides, serves, discloses or files any nonpublic documents or information in connection with this action, and who in good faith believes the information is confidential and implicates any such document or information contains nonpublic personal, private, financial, mental health, medical, social services, proprietary information, trade secrets, or other competitively sensitive information, or other confidential research, development or commercial information, or other information implicating privacy interests or proprietary interests of either the Plaintiffs, or the Defendants, or any other person, may designate such documents or information as "Confidential." The documents or information so designated shall be deemed "Confidential Material" subject to this Protective Order.
4. Confidential Material shall be used only for the limited purpose of preparing for and conducting this civil action (including any appeals), and not for any other purpose whatsoever, and shall not, without the consent of the party producing it or further order of the Court, be disclosed in any way to anyone except those specified in this paragraph:
a. attorneys involved with the litigationp
b. persons regularly employed by, or contracted with, or associated with the attorneys involved with the litigation whose assistance is deemed required by said attorneys in the preparation for trial or other proceedings in this case;
c. the parties and designated representatives of entity parties, as well as their insurers and reinsurersp
d. deponents, consultants, and witnesses (both lay and expert) who execute the attached Exhibit Ap
e. the Court and its employees ("Court Personnel");
f. stenographic reporters and videographers who are engaged in proceedings necessarily incident to the conduct of this action;
g. witnesses or potential witnesses who execute the attached Exhibit A;
h. copying/scanning services and their employees who will, or who may be, asked to work with counsel to reproduce, organize, image or otherwise work ...