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Creek Red Nation, LLC v. Jeffco Midget Football Association, Inc.

United States District Court, D. Colorado

January 19, 2016

CREEK RED NATION, LLC and HIGHLANDS RANCH YOUTH FOOTBALL ASSOCIATION, a non-profit corporation, Plaintiffs,
v.
JEFFCO MIDGET FOOTBALL ASSOCIATION, INC., Defendant.

PROTECTIVE ORDER

Defendant Jeffco Midget Football Association, Inc. ("JMFA"), through its undersigned counsel, has requested entry of a protective order. Upon a request of the parties in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery 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" shall be information that contains personal contact information, financial information, and/or confidential or commercially sensitive information for JMFA's business which is not generally available to the public. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

4. CONFIDENTIAL documents, materials, and/or information (collectively "CONFIDENTIAL 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) attorneys of record actively working on this case;
(b) persons regularly employed or associated with the attorneys of record 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; I
(c) the designated representatives of the entity 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 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. Documents are designated as CONFIDENTIAL by placing or affixing on them (in a manner that will not interfere with their legibility) the following or ...


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