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Lakeview Renovations, Inc. v. City and County of Denver

United States District Court, D. Colorado

December 10, 2015

LAKEVIEW RENOVATIONS, INC. dba NORTH AMERICAN PROPERTY SERVICES, INC. Plaintiff,
v.
CITY AND COUNTY OF DENVER, a municipal corporation, and SHEILA DIDUCH, Defendants.

SHERMAN & HOWARD L.L.C. Tamir I. Goldstein William R. Reed Attorneys for Plaintiff

Tracy A. Davis, #35058 Robert G. Wheeler, #28889 Joshua L. Roberts, #46139 Assistant City Attorney City and County of Denver City Attorney’s Office Attorneys for Defendants

JOINT AND STIPULATED PROTECTIVE ORDER

Kathleen M. Tafoya United States District Court Judge

Upon motion of all the parties for a Protective Order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, IT IS HEREBY ORDERED that:

1. All Confidential Discovery Material produced or exchanged in the course of this litigation shall be used solely for the prosecution, defense, and/or settlement of this litigation and for no other purpose whatsoever and shall not be disclosed to any person except in accordance with the terms of this Protective Order.

2. A producing party may designate as “Confidential” any document or information that it has determined in good faith consists of or relates to the following: (a) trade secrets, including but not limited to, employee lists, client lists, prospective client lists, bid and pricing information, records, forms, computer printouts, systems information, computer software, manuals, other business records and information, methods for the operation of the businesses; (b) financial, tax and accounting information, confidential or proprietary business-related information, business plans or projections, acquisition offers or expressions of interest, proposed strategic transactions or other business combinations, and competitive analyses; and (c) confidential personal information.

3. “Confidential Discovery Material, ” as used herein, means any information of any type, kind or character which is designated as “Confidential” by any of the supplying or producing parties, whether it be a document, information contained in a document, information revealed during a deposition, information revealed in an interrogatory answer or otherwise. In designating information as “Confidential, ” a party or third party will make such designation only as to the information that it in good faith believes contains confidential information and which that party has treated as confidential, proprietary, or trade secret information prior to the commencement of this litigation.

4. “Qualified Persons, ” as used herein, means:

a. This Court and relevant Court personnel;
b. Counsel for a party (including in-house counsel) and necessary secretarial, clerical and paralegal personnel assisting with the litigation of this action;
c. Any expert, consultant, jury consultant, or other person (and his or her direct staff and/or mock jurors) who is retained by counsel for the purpose of consulting and/or testifying in this litigation, provided that each such expert or consultant shall have previously signed the Acknowledgement of Protective Order, as provided in Exhibit A;
d. Persons who authored or received the document outside of this litigation, as shown on the face of the document;
e. Court reporters and videographers retained to transcribe or record testimony;
f. The parties, including any officer, director, agent, or employee of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this matter, provided that each such person shall have been advised of the Protective Order.
g. Deponents, witnesses, or potential witnesses to the extent counsel has a reasonable and good faith belief that such persons will be witnesses in this case and that the witnesses’ examination with respect to the Confidential Discovery Material is necessary in connection with such testimony, provided that each such person shall have signed the Acknowledgement of Protective Order, as provided in Exhibit A, except that ...

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