United States District Court, D. Colorado
Lee F. Johnston Tucker K. Trautman Case Collard DORSEY & WHITNEY LLP Attorneys for Defendant AT&T Corp.
Michael D. Murphy The Law Offices of Michael L. Glaser, LLC Attorneys for Plaintiff My24HourNews.Com, Inc.
STIPULATED PROTECTIVE ORDER FOR JURISDICTIONAL DISCOVERY
Nina Y. Wang United States Magistrate Judge
Plaintiff, My24HourNews.com, Inc. (“Plaintiff:”), and Defendant AT&T Corp. (“Defendant” or “AT&T Corp.”) (collectively, the “Parties”), through their undersigned counsel, stipulate as follows, pursuant to Federal Rule of Civil Procedure 26(c), that for the purposes of the jurisdictional discovery authorized by the Court’s October 22, 2015 Order (ECF 61), confidential information shall be disclosed only in the following designated ways.
Upon a showing of good cause in support of the stipulation, to protect the discovery and dissemination of confidential which will improperly annoy embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS HEREBY ORDERED:
1. As used in this Protective Order, these terms have the following meanings:
a. “Action” means the case styled My24HourNews.com v. AT&T Corp., Case No. 15-CV-01210-RM-NYW, in the United States District Court for the District of Colorado.
b. “Attorneys” means in-house counsel, and outside counsel of record representing or advising a Party in the action.
c. “Documents” are all materials within the scope of Fed.R.Civ.P. 34.
d. “Confidential” Documents are Documents designated pursuant to paragraph 2, below.
e. “Party” or “Parties” means the Plaintiff and Defendant in this action.
a. “Written Notification” and/or “Notice to Counsel” as required under the terms of this Protective Order shall with respect to Plaintiff require that such notice be delivered to: Michael D. Murphy, The Law Offices of Michael L. Glaser, LLC, 1720 S. Bellaire St., Suite 607, Denver, Colorado, 80222, email@example.com; and with respect to Defendant, to Lee F. Johnston, Dorsey & Whitney LLP, 1400 Wewatta Street, Suite 400, Denver, Colorado, 80202, firstname.lastname@example.org.
b. “Written Assurance” means an executed Document in the form attached hereto as Exhibit A.
2. A Party may designate information, whether in oral, written, paper, or electronic form, disclosed in this Action through discovery pursuant to the Federal Rules of Civil Procedure “Confidential” to protect information within the scope of Fed.R.Civ.P. 26(c)(1)(G) where the designating Party in good faith believes the Document contains confidential, proprietary, or commercially sensitive information. Information shall not be designated Confidential where it shows on its face to have been disseminated to the public. For Documents, information shall be designated Confidential at or prior to the time of production of the Documents by stamping or otherwise marking the documents as Confidential on each page to be deemed confidential. A party may designate information produced in an electronic format as Confidential by placing a confidentiality marking on the disk or device on which the documents are produced. Prior to designating any document or information as Confidential, counsel of record for a party must review the document and or information, to certify in good faith that such document and/or inform implicates common law or statutory privacy and/or confidentiality issues to warrant designation.
3. A Party receiving information designated Confidential may object to that designation and request the removal of such designation as outlined under the procedures set ...