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Lucio v. Ranger Fire, Inc.

United States District Court, D. Colorado

January 4, 2016

LEROY LUCIO, OSCAR FUENTES, RENE FUENTES, and RUDYMONCADA, On their own behalf and on behalf of all others similarly situated, Plaintiffs
v.
RANGER FIRE, INC. Defendant.

STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION

The parties, by and through their respective counsel, stipulate to the entry of this protective order concerning confidential information;

1. Purpose: The parties anticipate that during the course of this litigation, they will disclose or produce documents, testimony, and other information that contains proprietary, confidential, or personal information not publicly available, or and that implicates a privilege or legitimate privacy interest. The court enters this order to allow the parties to produce such confidential information while preserving it from unauthorized or unnecessary disclosure.

2. Scope: This protective order applies to all documents, materials, information, and deposition testimony marked "CONFIDENTIAL" by a party that a party provides or discloses to an opposing party during this litigation.

3. Documents: Fed.R.Civ.P. 34 (a) (1) (A) provides the definition of "document" in this order. A draft or non-identical copy is a separate document within the meaning of this term.

4. "CONFIDENTIAL INFORMATION" means documents, materials, information, and testimony a party provides or discloses during this litigation that is marked or designated "CONFIDENTIAL" and is proprietary, confidential, and not publicly available, or that implicates a privilege or legitimate privacy interest.

5. Lawyer Review: Documents a party intends to mark "CONFIDENTIAL" must first be reviewed by a lawyer for the party who will certify the "CONFIDENTIAL" designation is based on a good faith belief the information in the documents is confidential or otherwise entitled to protection.

6. Restrictions: Confidential information must not be disclosed or used for any purpose except the preparation and trial of this case.

7. Exceptions: Confidential information must not be disclosed without the consent of the party producing it or further order of the court, except such information may be disclosed to:

(a) Attorneys working on this case;
(b) persons regularly employed or associated with the attorneys working on the case whose assistance is required by said attorneys to prepare for trial, at trial, or at other proceedings in this case;
(c) the parties and designated representatives for the corporate defendant;
(d) expert witnesses and consultants retained in connection with this case, to the extent such disclosure is necessary for preparation, trial, or other proceedings in this case;
(e) the court and its employees;
(f) stenographic reporters engaged in proceedings necessarily incident to the ...

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