United States District Court, D. Colorado
CAMPBELL, KILLIN, BRITTAN & RAY, LLC, William C. Brittan, #17643, Margaret R. Pflueger, #39780, CAMPBELL, KILLIN, BRITTAN & RAY, LLC, Denver, CO.
SHEPPARD MULLIN RICHTER & HAMPTON, LLP, Arthur Friedman, San Francisco, California.
Harold Hamersmith, Los Angeles, California, ATTORNEYS FOR PLAINTIFF LEPRINO FOODS COMPANY.
THE ROSS-SHANNON LAW FIRM, P.C. Michael O. Frazier, #23189, Mark J. Gauthier, #21349, THE ROSS-SHANNON LAW FIRM, P.C., Lakewood, CO.
DORSEY & WHITNEY LLP, Gregory S. Tamkin, #27105, Denver, CO, ATTORNEYS FOR DEFENDANT DCI, INC.
STIPULATED PROTECTIVE ORDER
KATHLEEN M. TAFOYA, Magistarte Judge.
IT IS HEREBY STIPULATED by all parties to this action, by and through their respective attorneys of record herein, that disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The terms of this Protective Order are consistent with the Protective Order requirements set forth in Gillard v. Boulder Valley School District RE-2, 196 F.R.D. 382, Appendix A (D. Colo. 2000).
The parties acknowledge that this Stipulated Protective Order does not entitle them to file confidential information under seal. Local Rule 7.2 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.
Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:
A. Party or Parties: The employees of any party to this action, including employees of any party's department, division, or bureau or any party's parent or subsidiary companies, who have a need to know about information exchanged during the course of this action for the purposes of either monitoring or overseeing the action, or evaluating and advising counsel with respect to the action, together with outside counsel for any party and outside counsel's support staff.
B. Confidential Material: all information, regardless of the manner in which it is generated or maintained (including without limitation any deposition or other testimony, transcripts, or tangible things), that is protected under Colorado or federal law as confidential business information, trade secrets, or as being within the zone of privacy of an individual or entity. Confidential Material shall include, but not be limited to, any copies, excerpts, summaries, or compilations from such information, as well as testimony by witnesses or statements by counsel that reveal the contents of such information.
C. Retained Expert and Consultants: a person who has been retained by a Party or its counsel to serve as an expert ...