United States District Court, D. Colorado
Shimon Kohn, Esq., Ann Phillips Kaufman, Esq. and John Philip Winegar, Esq. WINEGAR LAW, LLC. ATTORNEYS FOR PLAINTIFF ALEXIS MARIE ACKER
Gordon L. Vaughan, Esq. and David R. DeMuro, Esq. ATTORNEYS FOR DEFENDANT WALKER, INDIVIDUALLY
STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
Plaintiff and Defendants and each Counsel of Record (collectively, the "Parties") stipulate and move the Court for a Protective Order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure concerning the treatment of Confidential Information (as hereinafter defined), and, as grounds therefor, state as follows:
1, In this action, counsel for the Parties are seeking Confidential Information (as defined in paragraph 2 below). The Parties also anticipate 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' business or privacy interests. The Parties have entered into this Stipulation and request the Court enter the 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 - not made available to the public- and designated by one of the Parties in the manner provided in paragraph 3.
3. Where Confidential Information is produced, provided, or otherwise disclosed by a Party ("Producing Party") it will be designated in the following manner:
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; and
c. With respect to transcribed testimony, by giving written notice to opposing counsel designating such portions as "Confidential" no later than thirty calendar days after receipt of the transcribed testimony.
4. Confidential material is subject to the following restrictions. Confidential material may be used only for the limited purpose of preparing for and conducting this civil action (including any appeals), and must not be disclosed in any way to anyone except:
a) attorneys actively working on this case;
(b) persons regularly employed or associated with the attorneys actively working on the case;
(c) the Parties, including Defendants' designated representatives and insurers;
(d) stenographic reporters who are engaged in proceedings ...