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Cross v. Discover Goodwill of Southern & Western Colorado

United States District Court, D. Colorado

November 10, 2015

BOBBY CROSS, Plaintiff,
v.
DISCOVER GOODWILL OF SOUTHERN & WESTERN COLORADO, Defendant.

CORNISH & DELL'OLIO Bradley J. Sherman, CO #39452 Attorneys for Plaintiff

SHERMAN & HOWARD L.L.C. Glenn H. Schlabs, CO # 18222 Attorneys for Defendant Discover Goodwill of Southern & Western Colorado

STIPULATED MOTION AND PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION

Nina Y. Wang United States Magistrate Judge

Plaintiff, Bobby Cross (“Plaintiff” or “Cross”), by and through his counsel, Bradley J. Sherman, of CORNISH & DELL'OLIO, and Defendant Discover Goodwill of Southern & Western Colorado, (“Defendant” or “Goodwill”), by and through its counsel, Glenn H. Schlabs of SHERMAN & HOWARD L.L.C., hereby stipulate and move the Court, finding good cause, hereby enters this for a Protective Order pursuant to Fed.R.Civ.P. 26(c) concerning the treatment of Confidential Information (as hereinafter defined), and, as grounds therefor, state as follows:

1. This 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 and designated as “CONFIDENTIAL” pursuant to the terms of this Protective Order.

2. As used in this Protective Order, the term “document” shall include, without limitation, any electronic or hard copy emails, writings, drawings, graphs, charts, photographs, phone records, and other data compilations from which information can be obtained. A draft or non-identical copy is a separate document within the meaning of this term.

3. Information designated “CONFIDENTIAL” shall be information that is confidential and implicates common law or statutory privacy interests of Goodwill or Plaintiff, and/or current or former employees of Goodwill. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial (including any appeal) of this case.

4. CONFIDENTIAL documents, materials, and/or information shall not, without the consent of the party producing it and the consent of the party claiming confidentiality (if that party is different from the producing party) or further Order of the Court, be disclosed or made available in any way to any person other than:

(a) attorneys actively working on this case;
(b) persons regularly employed by the attorneys actively working on the case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties, including designated representatives for Defendant;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for depositions, preparation, trial or other proceedings in this case;
(e) the Court and its employees (“Court Personnel”);
(f) stenographic reporters who are engaged in proceedings necessarily incident to the ...

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