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Chavez v. State

United States District Court, D. Colorado

January 29, 2016

THERESA CHAVEZ, Plaintiff,
v.
STATE OF COLORADO, DEPARTMENT OF EDUCATION and COLLEEN O’NEIL, JILL HAWLEY and NORMA LAWANSON, in their individual capacity, Defendants.

Jennifer Robinson ATTORNEY FOR PLAINTIFF

Melisa Panagakos Assistant Attorney General Office of the Attorney General Ralph L. Carr Colorado Judicial Center ATTORNEY FOR DEFENDANTS COLORADO DEPARTMENT OF EDUCATION, COLLEEN O’NEIL AND JILL HAWLEY

William A. Rogers, III Dietze and Davis, P.C. ATTORNEY FOR DEFENDANT NORMA LAWANSON

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 current or former employees, representatives or agents of COLORADO DEPARTMENT OF EDUCATION ("CDE"), including but not limited to Plaintiff Theresa Chavez, as well as third parties who have had contact with the Office of Professional Services and Educator Licensing. 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 CDE;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, ...

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