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Beall v. SST Energy Corp.

United States District Court, D. Colorado

November 5, 2015

SHANNON BEALL, Plaintiff,
v.
SST ENERGY CORPORATION, a Colorado Corporation, Defendant.

STIPULATED PROTECTIVE ORDER

Nina Y. Wang, United States Magistrate Judge.

The Parties represent that allegations, claims and defenses in this case may put at issue trade secrets or other confidential research, development, or commercial information of defendant, including without limitation confidential personnel information of employees. The allegations, claims and defenses may also put at issue the financial records and related information of plaintiff and other employees. Pursuant to Fed.R.Civ.P. 26(c), the need to protect the confidentiality of this information and disclose it only in designated ways is good cause for entry of a protective order. Accordingly, the court enters a protective order as follows.

1. Definitions.

As used herein, the terms set forth below shall have the following meaning:

a. “Action” means the above-referenced lawsuit captioned Beall v. SST Energy Corporation, Civil Action No. 1:15-cv-1741-MSK-NYW.

b. “CONFIDENTIAL INFORMATION” shall include, but not be limited to, trade secrets, financial data, and other technological, operational and/or proprietary information relating to Defendant's business that is not publicly available or known. Confidential information shall also include sensitive personnel information regarding Defendant’s current and/or former employees. In addition, Confidential information shall include sensitive personal information pertaining to named and opt-in plaintiffs.

c. “Documents” are all materials within the scope of Fed.R.Civ.P. 34.

d. “Confidential - Attorneys’ Eyes Only” documents are the subset of Confidential documents designated pursuant to paragraph 2.

e. “Discovery Material” shall mean documents, testimony, interrogatory answers or other information disclosed in this Action.

f. “Party” means any person, association, partnership, corporation or other entity that is named as a party in, or who opts in as a party to, this Action.

g. “Attorneys” means counsel of record in this Action.

h. “Producing Party” means any party to this Action who responds to a discovery request or otherwise provides information to another Party or the Court in connection with this Action.

i. “Receiving Party” means any Party who receives information from a Producing Party.

j. “Third Party” means any person, association, partnership, corporation or other entity that is not a party in this Action.

2. Designation of Information as “Confidential”

a. Any Party to this action may designate as “Confidential” any CONFIDENTIAL INFORMATION produced in this Action, including documents, discovery responses and transcripts containing CONFIDENTIAL INFORMATION. Such designation of “Confidential” will only be made after counsel of record reviews such information and certifies that such designation is appropriate ...


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