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The Guarantee Co. of North America USA v. TK Construction US, LLC.

United States District Court, D. Colorado

January 12, 2016

THE GUARANTEE COMPANY OF NORTH AMERICA USA, Plaintiff,
v.
TK CONSTRUCTION US, LLC; TK MINING SERVICES, LLC and affiliates; TK CONSTRUCTION, LLC d/b/a TK MINING SERVICES, LLC; BIG SKY, LLC; TK DIVERSIFIED SERVICES, LLC f/k/a UNLIMITED MANPOWER SOLUTIONS, LLC; TK HOLDINGS LTD and all subsidiaries, including, but not limited to TK INDUSTRIAL, LLC and TK BLASTING, LLC; AMY L. FISCHER; KEITH E. BUHRDORF; DAVID A. SCHAAF; and EARNEST E. SCHAAF. Defendants.

The Hustead Law Firm, P.C. Connor Cantrell, Patrick Q. Hustead, Esq. Connor Cantrell, Esq. Attorneys for The Guarantee Company of North America

KELLY & WALKER, LLC Shannon M. Bell Julie M. Walker, Esq. Shannon M. Bell, Esq. Attorneys for TK Mining Services, LLC and affiliates; TK Construction, LLC d/b/a TK Mining Services, LLC; Big Sky, LLC; TK Diversified Services, LLC f/k/a Unlimited Manpower Solutions, LLC; TK Holdings LTD and all subsidiaries, including, but not limited to: (TK Industrial, LLC and TK Blasting, LLC); Keith E. Buhrdorf; David A. Schaaf; and, Earnest E. Schaaf

STIPULATED PROTECTIVE ORDER

Kathleen M. Tafoya United States Magistrate Judge

This matter, having come before the Court on the written stipulation of the parties, by and through their respective counsel, and the foregoing parties having consented and agreed to the making and entry of this Order:

IT IS HEREBY ORDERED as follows:

1. Any document, interrogatory answer, deposition testimony, or other information obtained, either in hard copy, electronically, or otherwise, through discovery in the litigation of this case, or any portion thereof, may be designated as confidential by any party if such party, after review by an attorney, asserts that the information and/or documents constitutes, includes or discloses: (1) trade secret information (which is information not generally available to the public at large that has independent economic value as a result of not being publicly known in that it would be useful to a competitor), or (2) other confidential information that is commercially or competitively sensitive, proprietary and non-public, or (3) sensitive, non-public personal information concerning individuals, or (4) employee and/or personnel information or records, or (5) tax returns, financial statements and/or financial information (any of the foregoing may be designated as “Protected Material ”) .

2. Protected Material may be designated as confidential under this Order by use of the designation CONFIDENTIAL. With respect to documents, the designating party shall place the word above, or similar language, clearly on each such page or portion of the Protected Material designated for protection. In lieu of marking the original of a document, if the original is not produced, the designating party may mark the copies that are exchanged or produced.

3. Inadvertent failure to designate Protected Material as Confidential at the time of production may be remedied if, within forty-five (45) days after such Protected Material was produced without a “Confidential ” stamp, the producing party notifies all parties that such Protected Material had previously been produced without a “Confidential ” stamp. If Protected Material which was inadvertently produced without a “Confidential ” stamp is introduced as an exhibit during a hearing, the producing party must object at that hearing to the introduction of that Protected Material without a “Confidential ” stamp, or otherwise that objection shall be waived. If Protected Material which was inadvertently produced without a “Confidential ”stamp is introduced as an exhibit during a deposition, the producing party must object either orally at the deposition or in writing no later than thirty days after the date on which the transcript is available from the court reporter for distribution to counsel, or otherwise that objection shall be waived. The producing party shall stamp such newly designated material as “Confidential ”. All parties shall return to the party, or destroy, any unstamped copies of such Protected Material upon receipt of such Protected Material bearing the “Confidential ” stamp, provided, however, that the foregoing provision shall not apply to any documents that had already been filed with the Court or had otherwise become publicly available.

4. Protected Material classified under paragraph 2 above (“CONFIDENTIAL ” material) may be disclosed only to the following persons (“Qualified Persons ”), and only under the conditions set forth below (in ¶ 5), except upon the prior written consent of the designating party:

a. The Court.
b. Attorneys representing the parties, including in-house counsel, and regular employees of such attorneys assigned to and necessary to assist in the conduct of this action.
c. Bona fide consultants and experts retained by the parties and/or by the attorneys for the parties, to the extent necessary for the conduct of this action.
d. Outside vendors, such as court reporters, duplicating services and translation services, to the extent necessary for the prosecution or defense of this action.
e. Deponents noticed by the parties, to the extent necessary for the conduct of this action, the court reporters at such depositions, as well as any ...

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