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Nanda v. Phillips 66 Co.

United States District Court, D. Colorado

February 1, 2016

BALJIT S. NANDA, Plaintiff,
v.
PHILLIPS 66 COMPANY, Defendant.

HOLLAND & HART LLP BY CRAIG STEWART, P.C. ATTORNEYS FOR DEFENDANT

EDGAR LAW FIRM LLC BY DAVID W. EDGA ATTORNEYS FOR PLAINTIFF

STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

KATHLEEN M. TAFOYA UNITED STATES MAGISTRATE JUDGE

Upon consideration of the parties’ Joint Motion for Entry of Stipulated Protective Order, and it appearing to the Court that sufficient cause exists under Fed.R.Civ.P. 26(c) for the issuance of a Protective Order, it is ORDERED as follows:

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 to incorporate everything listed in Fed.R.Civ.P. 34(a)(1)(A). A draft or non-identical copy is a separate Document within the meaning of this term.

3. As used in this Protective Order, “Lawsuit” means this action and any appeals therefrom.

4. As used in this Protective Order, “Confidential Information” shall be information that is (1) confidential and implicates common law or statutory privacy interests of Plaintiff or of Defendant’s current or former employees, or (2) confidential and proprietary business information; and is designated as “Confidential” in the manner described in paragraph 10 below.

5. Prior to designating any information as Confidential Information under this Protective Order, counsel for the producing party shall review the information to be disclosed and designate the information it believes in good faith is Confidential Information or otherwise entitled to protection.

6. Confidential Information and all Documents produced in this Lawsuit shall be used only for the preparation and litigation of this Lawsuit, and shall not be disclosed or used for any other purpose including, without limitation, any business or commercial purpose or in connection with any other proceeding or litigation.

7. All persons with access to Confidential Information produced by another party or a nonparty shall take all reasonable precautions necessary to ensure that no other person shall disclose or use Confidential Information for any purpose that does not relate to this Lawsuit or in any manner that is not permitted by this Protective Order.

8. Confidential Information shall not, without the consent of the party producing it or further Court order, be disclosed, summarized, described, characterized or otherwise communicated or made available in whole or in part to any person except the following:

a. counsel of record in this Lawsuit;
b. persons employed by or associated with counsel of record in this Lawsuit whose assistance is required in connection with ...

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