United States District Court, D. Colorado
STIPULATED PROTECTIVE ORDER (PROPOSED)
KRISTEN L. MK U.S. MAGISTRATE JUDGE
Upon a request of the Parties of entry of a protective order to protect the discovery and dissemination of competitively sensitive, proprietary, and confidential information that may be utilized and sought in this case, 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" or "Attorneys' Eyes Only" shall be information that contains proprietary, confidential and/or commercially sensitive information, which is not available to the public, including but not limited to, agreements, contracts, trade data, research and development documents, customer identity and lists, pricing and rate structures or lists, and computer software programs in source code or object code. CONFIDENTIAL or "Attorneys' Eyes Only" information shall not be disclosed or used for any purpose except the preparation and trial of this case.
4. CONFIDENTIAL or "Attorneys' Eyes Only" documents, materials, and/or information (collectively "CONFIDENTIAL or Attorneys' Eyes Only information") shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:
(a) inside and outside counsel to the entity parties who are actively working on this case;
(b) persons employed by 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) designated representatives of the entity parties, unless the designation is "Attorneys' Eyes Only";
(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 this case;
(e) the Court and its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
(g) deponents, witnesses, or potential witnesses; and (h) other persons by written agreement of the parties.
5. "Attorneys' Eyes Only" information shall not be disclosed in any form to any representatives of the entity parties, other than to the entity parties' attorneys who are ...