United States District Court, D. Colorado
PROPOSED PROTECTIVE ORDER
Nina Y. Wang, United States Magistrate Judge
T his matter comes before the Court on the parties’ Joint Motion for Entry of Protective Order. [ECF No. 24]. The Court has reviewed that Motion. The parties have shown good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information. Therefore, IT IS ORDERED:
1. T his Protective Order shall apply to all confidential documents, materials, and information, produced, given, or exchanged by and among the parties and non-parties to t his action including, without limit a t ion, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, deposition exhibits, and any other confidential information disclosed pursuant to the disclosure or discovery duties created by the Federal Rule s 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 t his term.
3. As used in this Protective Order, “Allegedly Aggrieved Individuals” is defined to mean anyone the EEOC formally disc loses to Defendant as an individual on whose behalf it seeks relief in t his suit, including, but not limited to, Charging Parties Natalie Gilbert, Diane Morris f/k/a Diane Knox, Eva Pridmore, and Constance Hediger, and any as yet unidentified individuals the EEOC believes were subjected to unlawful employment practices by Defendant.
4. As used in this Protective Order, “designating party” is defined as any party who has designated documents, materials, and/or information as “CONFIDENTIAL.”
5. Information designated “CONFIDENTIAL” shall be information that implicates common la w privacy interests, statutory privacy interests, and/or confidentiality interests such as: (a) personnel records of the Allegedly Aggrieved Individuals and Defendant’s current or former employees and/or applicants for employment; (b) Defendant’s trade secrets; (c) privileged or confidential commercial information; (d) privileged or confidential financial information; (e) medical records, financial records, and tax records pertaining to the Allegedly Aggrieved Individuals, Defendant’s current and former employees or applicants for employment, and any other witness in t his case. CONFIDENTIAL information shall not be disclosed for any purpose except for the preparation ad trial of this case and as prescribed by law by 5 U.S.C. § 552, Freedom of Information Act (FOIA), as amended.
6. CONFIDENTIAL documents, materials, and/or information (collectively “CONFIDENTIAL information”) shall not, without the consent of the designating party or further Order of the Court, be disclose d except that such information ma y be disclose d 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 s a id attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties and the designated representatives for the parties;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in t h is case;
(e) the Court and it s employees (“Court Personnel”);
(f) stenographic reporters who are engaged in proceedings necessarily incident to the ...