United States District Court, D. Colorado
Keith Frankl, The Franl Law Firm, P.C., 2170 S. Ash St., Denver, CO, Attorney for Plaintiff Levette Kyeremeh.
JOHN F. WALSH, United States Attorney. J. Chris Larson, Edwin Winstead, Assistant United States Attorneys, Denver, CO, Attorneys for Defendant the United States of America.
STIPULATED PROTECTIVE ORDER
RICHARD P. MATSCH, District Judge.
This matter comes before the court on a Joint Motion for Entry of Stipulated Protective Order. Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information, information protected by the Privacy Act of 1974 or information that will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:
A. Order to produce documents containing sensitive information.
1. Plaintiff has requested in discovery documents that may contain information protected by the Privacy Act, or that is otherwise confidential, pertaining to a current employee of the United States Postal Service ("USPS").
2. Pursuant to 5 U.S.C. § 552a(b)(11), Defendant is ordered to provide Plaintiff's counsel access to these documents.
B. Terms of the Stipulated Protective Order.
3. This Stipulated 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.
4. As used in this Stipulated 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.
5. Information designated "CONFIDENTIAL" shall be information that is confidential and implicates common law and statutory privacy interests of any USPS employee.
6. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL information") shall not be disclosed or used for any purpose except the preparation and trial of this case.
7. CONFIDENTIAL information shall not, without the consent of the party producing it or further Order of the Court, be disclosed except ...