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Estate of Vallina v. The County of Teller Sheriff's Office

United States District Court, D. Colorado

December 14, 2015

THE ESTATE OF ROBERT VALLINA; JUAN J. VALLINA, personally; and MARTHA VALLINA, personally and as personal representative of the estate of Robert Vallina, deceased; Plaintiffs,
v.
THE COUNTY OF TELLER SHERIFF'S OFFICE, and its DETENTION FACILITY; SHERIFF MIKE ENSMINGER, in his individual and official capacities; DEPUTY CHRISTIANSON, in his or her individual and official capacities; DEPUTY JOHNSON, in his or her individual and official capacities; and, JOHN/JANE DOE 1-20, in their respective individual and official capacities. Defendants.

MACEAU LAW Greg Maceau John M. Scorsine Mark A. Barrionuevo Maceau Law Attorneys for Plaintiffs

WELLS, ANDERSON & RACE LLC Cathy Havener Greer Rachel Ollar Entrican Wells, Anderson & Race LLC Attorneys for Defendants

STIPULATION AND PROTECTIVE ORDER

CRAIG B. SHAFFER U.S. MAGISTRATE JUDGE

Plaintiffs and Defendants County of Teller Sheriff’s Office, Sheriff Mike Ensminger, Deputy Ian Christiansen, and Officer Kevin Johnson (collectively referred to as the “Parties”), by and through their respective counsel, stipulate and move the Court for a Protective Order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and Rule 502(d) of the Federal Rules of Evidence concerning the treatment of Confidential Information (as hereinafter defined) and documents covered by the attorney-client privilege or work product doctrine. As grounds therefore, the Parties state as follows:

1. In this action, at least one of the Parties will produce or has sought and/or may seek Confidential Information (as defined in paragraph 2 below). 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 one or more of the Parties’ security, safety, or privacy interests. The Parties have entered into this Stipulation and request the Court enter the within Protective Order for the purpose of preventing the disclosure and use of Confidential Information except as set forth herein.

2. “Confidential Information” means any document, file, portions of files, transcribed testimony, or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom, which contains information that a party believes is confidential and implicates common law and statutory privacy interests of the individuals who are named and which are not made available to the public, as to which a reasonable expectation of privacy or confidentiality exists.

3. Information designated as Confidential must first be reviewed by the attorney for the designating party, who must have a good faith belief that the information is confidential or otherwise entitled to protection under Fed.R.Civ.P. 26(c). Gillard v. Boulder Valley Sch Dist., 196 F.R.D. 382, 386 (D. Colo. 2000).

4. Where Confidential Information is produced, provided, or otherwise disclosed by the Parties in response to any discovery request, it will be designated in the following manners:

a. By imprinting the word “Confidential” on the first page or cover of any document produced;
b. By imprinting the word “Confidential” next to or above any response to a discovery request;
c. With respect to transcribed testimony, by designating such testimony “Confidential” at the time of the deposition or hearing; or by giving written notice to opposing counsel designating such portions as “Confidential” no later than thirty (30) calendar days after receipt of the transcribed testimony; and
d. With respect to live testimony, by making a record at the time of the testimony.

5. Confidential Information is subject to the following restrictions:

a. It shall be used only for the purpose of this litigation and not for any business or other ...

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