United States District Court, D. Colorado
Anthony D. Edwards San juan law office, L.L.C. Attorney for Plaintiff Janice L. Naegle
Douglas r. ware, LLC Attorney for Defendant Animas Surgical Hospital, LLC
STIPULATED PROTECTIVE ORDER
Under Fed.R.Civ.P. 26(c), and in consideration of the parties' stipulation for a Protective Order concerning confidential information, as defined by law, disclosed and/or to be disclosed during discovery in this matter, and it appearing to the Court that sufficient cause exists for the issuance of a Protective Order, it is
ORDERED 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 this Order.
2. As used in this Protective Order, "document" is defined as provided by Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. One who provides, serves, discloses or files any nonpublic documents or information in connection with this civil action, and who in good faith believes such documents or information contain nonpublic personal, employment, financial, proprietary and/or trade secret information, or otherwise implicate the privacy interests of plaintiff, defendant, or third parties, may designate such documents or information as "Confidential." The documents or information so designated shall be deemed "Confidential Material" subject to this Protective Order. In addition, any such information obtained from third parties, via subpoena or other means, may also be deemed "confidential" by the above method of designation. In order to facilitate review of documents obtained by third parties for confidentiality, the obtaining party shall forward documents obtained from a third party within ten (10) business days to the opposing party.
4. Confidential Material shall be subject to the following restrictions. Confidential Material shall be used only for the limited purpose of preparing for and conducting this civil action (including any appeals), and not for any other purpose whatsoever, and shall not, without the consent of the party producing it or further Order of the Court, be disclosed in any way to anyone except those specified in this paragraph:
(a) attorneys actively working on this case;
(b) persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by said attorneys in the preparation for trial, or at other proceedings in this case;
(c) the parties and employees of the parties having a legitimate litigation need to review Confidential Material;
(d) witnesses or potential witnesses;
(e) outside copy/graphics services;
(f) the Court and its employees ("Court ...