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Estate of Martinez v. Board of County Commissioners of County for Pueblo County Colorado

United States District Court, D. Colorado

November 19, 2015

ESTATE OF TANYA MARTINEZ; JUDY ARMIJO, as Personal Representative of the Estate of Tanya Martinez; ESAI MARTINEZ, a minor, by and through his grandmother, Judy Armijo; and ANGEL MARTINEZ, Plaintiff,
v.
The BOARD OF COUNTY COMMISSIONERS OF THE COUNTY FOR PUEBLO COUNTY COLORADO; a governmental entity; KIRK TAYLOR, in his official capacity as Pueblo County Sheriff; CORRECTIONAL HEALTHCARE COMPANIES, INC.; CORRECTIONAL HEALTHCARE PHYSICIANS, P.C.; CORRECT CARE SOLUTIONS, LLC; MIKE WHITE, E.M.T., in his individual and official capacities; JENNIFER SCOTT, R.N., in her individual and official capacities; KIM MURRAY, L.P.N., in her individual and official capacities; NORMA MOWER, PA-C, in her individual and official capacities; DEPUTY CINDY GOMEZ, in her individual and official capacities; DEPUTY DEANA COOK, in her individual and official capacities; and, DEPUTY ANNADENE LUCERO, in her individual and official capacities, Defendants.

Matthew J. Cron, Siddhartha H. Rathod, RATHOD MOHAMEDBHAI LLC, Gregory A. Gold Colleen Parsley, THE GOLD LAW FIRM, L.L.C., ATTORNEYS FOR PLAINTIFF

Ann B. Smith VAUGHAN & DeMURO, ATTORNEYSFORCOUNTY DEFENDANTS

C. Gregory Tiemeier Dan Mauk Tiemeier & Stich, P.C., ATTORNEYSFORCCS/CHC DEFENDANTS

STIPULATED PROTECTIVE ORDER

R. BROOKE JACKSON UNITED STATES DISTRICT JUDGE.

Pursuant to Fed.R.Civ.P. 26(c), upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:

1. This Stipulated 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.

2. As used in this Stipulated Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a). 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 and statutory privacy interests or security interests of: (a) Plaintiffs Estate of Tanya Martinez, Judy Armijo, Esai Martinez, and Angel Martinez; or (b) Defendants the Board of County Commissioners of the County for Pueblo County, Colorado, Sheriff Kirk Taylor, Deputy Cindy Gomez, Deputy Deana Cook, Deputy Annadene Lucero, Correctional Healthcare Companies, Inc., Correctional Healthcare Physicians, P.C., Correct Care Solutions, LLC, Mike White, E.M.T., Jennifer Scott, R.N., Kim Murray, L.P.N., and Normal Mower, PA-C, including confidential, security-sensitive, proprietary, trade secret, financial, or personal information. Any information designated by a party as CONFIDENTIAL must first be reviewed by a lawyer who will certify that the designation as CONFIDENTIAL is based on a good faith belief that the information “is confidential or otherwise entitled to protection.” Gillard v. Boulder Valley Sch. Dist., 196 F.R.D. 382, 386 (D. Colo. 2000). CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

4. 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 parties’ attorneys that are actively working on this case;
b. persons regularly employed or associated with the parties’ attorneys that are actively working on the case whose assistance is required by said attorneys in the preparation of the case, at trial, or at other proceedings in this case;
c. the parties, including designated representatives for the Plaintiffs and Defendants;
d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, ...

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