United States District Court, D. Colorado
ROGER J. LUCAS, Plaintiff,
THE OFFICE OF THE COLORADO STATE PUBLIC DEFENDER, a public entity, DOUGLAS K. WILSON, individually and in his official capacity as the COLORADO PUBLIC DEFENDER, and CARRIE THOMPSON, individually, and in her official capacity as the OFFICE HEAD for the COLORADO SPRINGS PUBLIC DEFENDER’S REGIONAL OFFICE Defendants.
The Law Office of Roger J. Lucas, L.L.C. PLAINTIFF, PRO SE
Douglas J. Cox Senior Assistant Attorney General Office of the Attorney General Ralph L. Carr Colorado Judicial Center ATTORNEY FOR DEFENDANTS
STIPULATED PROTECTIVE ORDER
CRAIG B. SHAFFER UNITED STATES MAGISTRATE JUDGE
Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of Confidential Information, IT IS HEREBY ORDERED:
1. This Protective Order shall apply to all documents, materials, and information appropriately designated as Confidential as outlined in paragraphs 3 through 7 herein. This includes without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information or documents 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 is confidential, trade secret, or implicates common law and/or statutory privacy interests of non-parties, including non-party, current and former employees of the Office of the Colorado State Public Defender. Designation of information as Confidential shall not affect its discoverability. Confidential Information shall be used for the sole, strict and limited purpose of the preparation and trial of this action and shall not be used for any other purpose.
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 actively working on this case;
(b) persons regularly employed 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) the Parties, including designated representatives for plaintiff and defendant;
(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/or its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the ...