United States District Court, D. Colorado
MELLISSA CLARKE CRICHTON, and CRISTY HEDGPETH, individually and on behalf of all others similarly situated, Plaintiffs,
AUGUSTUS ENERGY RESOURCES, L.L.C. Defendant.
STACY A. BURROWS ATTORNEY FOR PLAINTIFFS
ANDREA WANG ATTORNEY FOR DEFENDANT
STIPULATED PROTECTIVE ORDER
KRISTEN L. MIX MAGISTRATE JUDGE
Plaintiffs Mellissa Crichton and Cristy Hedgpeth and Defendant Augustus Energy Resources, L.L.C. (referred to collectively as the "Parties") have stipulated to the terms of this Protective Order.
This Protective Order is designed to preserve the confidentiality of certain testimony given by witnesses in this case and certain information contained in documents or correspondence exchanged or produced in this case pursuant to the terms of this Protective Order. Documents or testimony deemed to be confidential shall be so designated in accordance with this Protective Order.
To expedite the flow of discovery material and the litigation of this case, facilitate the prompt resolution of disputes over confidentiality, and adequately protect material entitled to be kept confidential, it is, by agreement of the Parties and pursuant to the Court's authority under the Federal Rules of Civil Procedure, STIPULATED AND ORDERED that:
1. This Protective Order shall apply to all documents, materials, and information exchanged or produced by the Parties or non-parties, including, but not limited to, documents produced, correspondence, and other information disclosed pursuant to the Federal Rules of Civil Procedure that are designated "CONFIDENTIAL" (collectively "Confidential Information") in accordance with this Protective Order.
2. As used in this Protective Order, "document" is defined as provided in Fed.R.Civ.P. 34(a)(1). A draft or non-identical copy is a separate document within the meaning of this term.
3. Information designated "CONFIDENTIAL" shall only be information that is confidential business, financial or proprietary material, or otherwise private, confidential, sensitive, or otherwise not available to the public. Confidential Information shall not be disclosed or used for any purpose except the preparation and trial of this case.
4. Confidential Information designated as "CONFIDENTIAL" 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 who are actively working on this case and in-house attorneys;
(b) persons regularly employed or associated with the attorneys actively working on the case or in-house attorneys, whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings;
(c) the Parties, including employees of the Defendant;
(d) expert witnesses, consultants, and private investigators retained in connection with this proceeding, to the extent such disclosure is necessary for ...