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Morgan v. City of Colorado Springs

United States District Court, D. Colorado

December 22, 2015

LARRY MORGAN, Plaintiff,
v.
CITY OF COLORADO SPRINGS, Defendant,

PROTECTIVE ORDER

This matter comes before the Court on the parties' Stipulated Motion for Protective Order. The Court has reviewed that Motion. The Motion is meritorious and acceptable. Therefore, IT IS ORDERED:

1. This 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 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 such as, but not limited to: personnel and/or payroll records of current or former employees of Defendant the City of Colorado Springs; personal, medical, financial information, or other information implicating privacy interests; trade secret or other confidential research, development, or commercial information entitled to protection under Fed.R.Civ.P. 26(c)(1)(G); or operations or business information implicating public safety not generally known to the public. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

4. Any information to be designated by a Party as CONFIDENTIAL must first be reviewed by a lawyer and be determined to be subject to protection as confidential under the terms of this Protective Order, as described in paragraph 3, above, before being marked CONFIDENTIAL. The Party designating the information as CONFIDENTIAL shall prepare a log identifying by Bates Number each document designated as CONFIDENTIAL and stating by Bates Number the following: (a) the specific basis or bases relied on by the Party for designating the information CONFIDENTIAL; and (b) legal authority, if any, supporting the claim of confidentiality. The required "confidentiality log" shall accompany the production of any information designated CONFIDENTIAL.

5. "FOR ATTORNEY EYES ONLY" shall be information that includes employee or officer-identifying information.

6. CONFIDENTIAL and FOR ATTORNEYS EYES ONLY documents, materials, and/or information shall be used solely for the purpose of this action, and shall not, without the consent of the party producing it, or further Order of the Court, be used, transferred, disclosed or communicated in any way, except that CONFIDENTIAL information may be disclosed to:

(a) attorneys actively working on this case;
(b) persons regularly employed or associated with the attorneys actively working on the case whose assistance is required by said attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties, including designated representatives;
(d) expert witnesses and consultants retained in connection with this proceeding, their employees or agents assisting them, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
(e) the Court and its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the ...

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