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Kelly v. Aramark Uniform Services

United States District Court, D. Colorado

November 13, 2015

JOE KELLY, Plaintiff,
v.
ARAMARK UNIFORM SERVICES, Defendant.

PROTECTIVE ORDER

R. BROOKE JACKSON UNITED STATES DISTRICT JUDGE.

The Court recognizes that at least some of the documents and information (“materials”) being sought through discovery in the above-captioned action are, for certain reasons, normally kept confidential by the parties, Plaintiff Joe Kelly (“Plaintiff”), and Defendant Aramark Uniform & Career Apparel, LLC, incorrectly sued as Aramark Uniform Services, (“Defendant”). The parties have reviewed the Court’s local rules and practice standards and have tailored this [Proposed] Protective Order (“Order”) accordingly and have agreed to be bound by the terms of this Order in this action.

The materials to be exchanged throughout the course of the litigation between the parties may contain Social Security numbers, residential addresses, health information, and true trade secret or other confidential research, technical, cost, price, marketing or other commercial information, as is contemplated by Federal Rule of Civil Procedure 26(c)(7). The purpose of this Order is to protect the confidentiality of such materials as much as practical during the litigation. THEREFORE:

DEFINITIONS

1. The term “Confidential Information” will mean and include information contained or disclosed in any materials, including documents, portions of documents, answers to interrogatories, responses to requests for admissions, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, including data, summaries, and compilations derived therefrom that is deemed to be Confidential Information by any party to which it belongs.

2. The term "materials" will include, but is not be limited to: documents; correspondence; memoranda; bulletins; blueprints; specifications; customer lists or other material that identify customers or potential customers; price lists or schedules or other matter identifying pricing; minutes; telegrams; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; notes of conversations; desk diaries; appointment books; expense accounts; recordings; photographs; motion pictures; compilations from which information can be obtained and translated into reasonably usable form through detection devices; sketches; drawings; notes (including laboratory notebooks and records); reports; instructions; disclosures; other writings; models and prototypes and other physical objects.

3. The term "counsel" will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in the law firms identified below:

• Counsel for Plaintiff: BACHUS & SCHANKER, LLC.
• Counsel for Defendant: WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP and MORGAN, LEWIS & BOCKIUS LLP.

"Counsel" also includes in-house attorneys for Defendant.

GENERAL RULES

4. Each party to this litigation that produces or discloses any materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to this Protective Order may designate the same as "CONFIDENTIAL" or "CONFIDENTIAL - FOR COUNSEL ONLY."

a. Designation as "CONFIDENTIAL": Any party may designate information as "CONFIDENTIAL" only if, in the good faith belief of such party and its counsel, the unrestricted disclosure of such information could be potentially prejudicial to the business or operations of such party.
b. Designation as "CONFIDENTIAL - FOR COUNSEL ONLY": Any party may designate information as "CONFIDENTIAL - FOR COUNSEL ONLY" only if, in the good faith belief of such party and its counsel, the information is among that considered to be most sensitive by the party, including but not limited to trade secret or other confidential research, development, financial or other commercial information.

5. In the event the producing party elects to produce materials for inspection, no marking need be made by the producing party in advance of the initial inspection. For purposes of the initial inspection, all materials produced will be considered as "CONFIDENTIAL - FOR COUNSEL ONLY, " and must be treated as such pursuant to the terms of this Order. Thereafter, upon selection of specified materials for copying by the inspecting party, the producing party must, within a reasonable time prior to producing those materials to the inspecting party, mark the copies of those materials that contain Confidential Information with the appropriate confidentiality marking.

6. Whenever a deposition taken on behalf of any party involves a disclosure of Confidential ...


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