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Ensign United States Drilling Inc. v. Weatherford Us Limited Partnership

United States District Court, D. Colorado

February 6, 2014

ENSIGN UNITED STATES DRILLING INC. and ENSIGN UNITED STATES DRILLING (CALIFORNIA) INC., Plaintiffs,
v.
WEATHERFORD U.S. LIMITED PARTNERSHIP, Defendant.

Maureen Reidy Witt, Claire E. Wells Hanson, Holland & Hart LLP, Denver, CO, Attorneys for Defendant.

SHERMAN & HOWARD, L.L.C., Tamir Goldstein, Reed W. Morgan, Denver, Colorado, Attorneys for Plaintiffs.

STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

KATHLEEN M. TAFOYA, Magistrate Judge.

Upon consideration of the parties' Renewed Joint Motion for Entry of Stipulated Protective Order, and it appearing to the Court that sufficient cause exists under F.R.C.P. 26(c) for the issuance of a Protective Order, it is ORDERED 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 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. As used in this Protective Order, "Lawsuit" means this action and any appeals therefrom.

4. As used in this Protective Order, "Confidential Information" shall be information that is (1) confidential and implicates common law and statutory privacy interests of Defendant's or Plaintiffs' current or former employees and (2) confidential and proprietary business information.

5. Prior to designating any information as Confidential Information under this Protective Order, counsel for the producing party shall review the information to be disclosed and designate the information it believes in good-faith is Confidential Information or otherwise entitled to protection.

6. Confidential Information shall be used only for the preparation and litigation of this Lawsuit, and shall not be disclosed or used for any other purpose including, without limitation, any business or commercial purpose or in connection with any other proceeding or litigation.

7. All persons with access to Confidential Information produced by another party or a nonparty shall take all reasonable precautions necessary to ensure that no other person shall disclose or use Confidential Information for any purpose that does not relate to this Lawsuit or in any manner that is not permitted by this Protective Order.

8. Confidential Information shall not, without the consent of the party producing it or further Court order, be disclosed, summarized, described, characterized or otherwise communicated or made available in whole or in part to any person except the following:

a. counsel of record in this Lawsuit;
b. persons employed by or associated with counsel of record in this Lawsuit whose assistance is required in connection with ...

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