United States District Court, D. Colorado
Charles W. Steese Sandra L. Potter Armstrong Teasdale LLP Attorneys for Plaintiff Sprint Communications Company L. P.
Rebecca B. DeCook Patrick J. Hickey Moye White LLP and Hans J. Germann Robert E. Entwisle Mayer Brown LLP Attorneys for Defendant AT&T Corp.
STIPULATED PROTECTIVE ORDER GOVERNING CONFIDENTIAL INFORMATION (DOCKET NO. 27.1)
Plaintiff, Sprint Communications Company L.P. ("Sprint"), and Defendant, AT&T Corp. ("AT&T") (hereinafter Sprint and AT&T are referred to as the "Parties" or each individually is referred to as a "Party") hereby agree to entry of this Stipulated Protective Order Governing Confidential Information ("Protective Order") in order to preserve the confidentiality of certain information that may be contained in documents produced and certain testimony that may be given by witnesses in this case. Accordingly, IT IS ORDERED THAT:
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. Any Party, through counsel or otherwise, may designate any document, or any part of any document, as CONFIDENTIAL if that Party has a bona fide, good faith belief that the information contained therein should be protected from public disclosure.
3. CONFIDENTIAL Information shall be used only for purposes of this case. CONFIDENTIAL Information shall not be used in any other litigation or proceeding or for any other purpose, absent a written agreement signed by all of the Parties to this Protective Order, or by order of this Court.
4. CONFIDENTIAL Information shall be identified by placing or affixing on every page (in a manner that will not interfere with their legibility) the following or other appropriate notice: "CONFIDENTIAL." Any information designated by a Party as CONFIDENTIAL must first be reviewed by a lawyer who will certify that the designation as CONFIDENITAL is based on a good faith belief that the information is CONFIDENTIAL or otherwise entitled to protection under Fed.RXiv.P 26(c).
5. CONFIDENTIAL Information 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) the Court and its employees ("Court Personnel");
(b) copy, data, hosting, and other providers of litigation services retained by counsel for the Parties for the purposes of the action;
(c) the Parties and their employees who have a need to know about the information;
(d) in-house and outside attorneys for the Parties, and those attorneys' respective employees;
(e) court reporters and videographers transcribing or filming depositions or testimony involving Confidential Information;
(f) expert witnesses and consultants retained in connection with this civil action, to the extent such disclosure is necessary for preparation, trial or ...