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Hulse v. Adams County

United States District Court, D. Colorado

October 23, 2015

JEFFREY HULSE, et al., Plaintiffs,
v.
ADAMS COUNTY, COLORADO, et al., Defendants.

Juliane T. DeMarco, Assistant County Attorney Adams County Attorney's Office, Brighton, CO, Attorney for Defendants

Darold Killmer, Michael Fairhurst, Killmer Lane & Newman, Denver, Colorado, Attorneys for Plaintiffs.

[PROPOSED] PROTECTIVE ORDER

NINA Y. WANG, Magistrate Judge.

This Protective Order shall apply to all information, documents, and things subject to discovery in this action, whether produced by a party or third party, including, without limitation: documents and information produced pursuant to Rule 26, testimony adduced at depositions upon oral examination or upon written questions pursuant to Rules 30 and 31, answers to Interrogatories pursuant to Rule 33, documents produced pursuant to Rule 34, information obtained from inspection of premises or things pursuant to Rule 34, and answers to requests for admission pursuant to Rule 36.

1. "Confidential Information" means any document, file, portions of files, deposition or transcribed testimony, or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom, which contains information that is confidential and implicates common law and statutory privacy interests of the individuals who are named.[1]

2. Information designated as confidential must first be reviewed by the attorney for the designating party, who must have a good faith belief that the information is confidential or otherwise entitled to protection under Fed.R.Civ.P. 26(c). Gillard v. Boulder Valley Sch. Dist., 196 F.R.D. 382, 386 (D. Colo. 2000).

3. When Confidential Information is produced, provided or otherwise disclosed by a Party in response to any discovery request, it will be designated in the following manner by:

a. imprinting the word "Confidential" on the first page or cover of any document produced;
b. imprinting the word "Confidential" next to or above any response to a discovery request; and
c. designating deposition testimony as "Confidential" or containing "Confidential Information" on the record at the time of the deposition, or by designating portions of depositions as "Confidential" after transcription, provided written notice of the designation is given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript.

7. All Confidential Information provided by a party in response to a discovery request or transcribed testimony shall be subject to the following restrictions:

a. It shall be used only for the purposes of this litigation and not for any other purpose;
b. It shall not be communicated or disclosed by any party's counsel or a party in any manner, either directly or indirectly, except for purposes of this litigation, to anyone ...

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