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Dipaulo v. Board of County Commissioners for County of Arapahoe

United States District Court, D. Colorado

December 1, 2015

CRISTIAN DIPAULO, Plaintiff,
v.
BOARD OF COUNTY COMMISSIONERS FOR COUNTY OF ARAPAHOE, et al., Defendants.

Paul Gordon Gordon & McWhirter, LLC Counsel for Plaintiff

Edward M. Caswall Sr. Assistant County Attorney Arapahoe County Attorney's Office Counsel for Defendants

STIPULATED PROTECTIVE ORDER

This matter is before the Court upon the Plaintiff Cristian DiPaulo and Defendants Board of County Commissioners, Arapahoe County Sheriffs Office and Starbuck's ("Defendants") Stipulated Motion for Protective Order (Doc. #33) designed and intended to preserve the confidentiality and privacy of documents and other information to be exchanged between them pursuant to their respective disclosure obligations and discovery efforts in the above-captioned action, and the Court being fully advised in the premises and for good cause appearing, the parties' Stipulated Motion for Protective Order is GRANTED and IT IS ORDERED as follows:

1. It is contemplated that both Plaintiff and Defendants will seek and exchange Confidential Information (as defined below in Paragraph 2) from and between each other in this action as part of their respective disclosure and discovery efforts.

2. "Confidential Information" means any document, file, record, oral testimony, transcribed testimony or recording, photograph, or other tangible thing, either in whole or in part, and any response to a discovery request, including any extract, abstract, chart, summary, note or copy made therefrom, that contains information that is confidential and implicates common law and/or statutory or constitutional privilege or privacy interests and has been designated by one of the parties in this action in the manner provided in Paragraph 3 below as containing Confidential Information, including, but not limited to, the following:

a) Employment personnel files, including complaint, disciplinary and/or internal affairs records.
b) Medical records, including psychological counseling and mental health records.
c) Tax or personal financial records.
d) Those portions of transcribed deposition or other witness testimony disclosing Confidential Information.

3. Where Confidential Information is produced, exchanged, provided, or otherwise disclosed by one party to the other party in response to any disclosure or discovery request or obligation, it shall be designated as Confidential Information in the following manner:

a) By imprinting or stamping the word "Confidential" on the first page or cover of any document, record, or thing produced;
b) By imprinting or stamping the word "Confidential" next to or above any response to a discovery request; and
c) With respect to any transcribed testimony, by giving written notice to opposing counsel designating such testimony, or portions thereof, as "Confidential" not later than twenty-one (21) calendar days after receipt of the transcribed testimony. Prior to the expiration of the 21 day period, the parties will treat transcribed testimony as Confidential Information upon an oral statement on the record by counsel, unless the parties agree otherwise. Any oral deposition testimony may be designated as Confidential Information prior to the receipt of transcribed testimony unless agreed upon by both sides on the record, but must be later designated as Confidential Information pursuant to this paragraph 3(c) to be treated as Confidential Information.

4. Any information designated by a party as confidential must first be reviewed by a lawyer who must be able to certify that the designation as confidential is based on a good faith belief that the information is confidential or ...


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