United States District Court, D. Colorado
COUNSEL FOR THE PLAINITIFF: James PaganoCook & Pagano, P.C.,
COUNSEL FOR THE DEFENDANT: Jacquelyn S. Booker Sutton | Booker | P.C.
STIPULATED PROTECTIVE ORDER
NINA Y. WANG UNITED STATES MAGISTRATE JUDGE.
This matter having come before the Court on the Unopposed Motion for Protective Order, hereby finds and orders as follows:
1. In this action, both parties have previously sought and/or will seek Confidential Information. The Parties also anticipate seeking additional Confidential Information during discovery and that there will be questioning concerning Confidential Information in the course of depositions. The Parties assert the disclosure of such information outside the scope of this litigation could result in significant injury to the interests of the Parties. The Protective Order is entered for the purpose of preventing the disclosure and use of Confidential Information except as set forth herein.
2. "Confidential Information" means any document certified by counsel as confidential based on a good faith belief that the information is confidential or otherwise entitled to protection under confidentiality or privacy protections recognized by rule, statute or common law and labeled on each page of the document with the word "confidential". The term "document" is defined as provided in Fed.R.Civ.P. 34(a).
3. American Family Mutual Insurance Company may produce certain documents that it considers proprietary, confidential, and competitively sensitive and/or trade secrets of Defendant or its related entities or which implicate an individual's common law or statutory privacy interests.
4. Plaintiff may produce Plaintiffs' medical and other health care records during this litigation that contain Plaintiffs' social security numbers and private medical information.
5. All Confidential Information provided by a Party shall be subject to the following restrictions:
a. It shall be used only for the purpose of this litigation and not for any business or other purpose whatsoever;
b. It 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:
i. attorneys actively working on this case;
ii. 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, at ...