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Shuck v. Academy School District 20

United States District Court, D. Colorado

February 1, 2016

DIANE H. SHUCK, Plaintiff,
v.
ACADEMY SCHOOL DISTRICT 20, LINDA VAN MATRE, TRACEY JOHNSON, CATHERINE BULLOCK, LARRY BORLAND, GLENN STREBE, MARK HATCHELL, DAVID PEAK, SUSAN FIELD, TORIA MCGILL, in their official and individual capacities, Defendants.

JOEL W. CANTRICK JOEL W. CANTRICK, P.C. ATTORNEYS FOR PLAINTIFF DIANE H. SHUCK

ERIN A. WEBBER MICHELLE L. GOMEZ LITTLER MENDELSON, P.C. ATTORNEYS FOR DEFENDANTS ACADEMY SCHOOL DISTRICT 20, LINDA VAN MATRE, TRACEY JOHNSON, CATHERINE BULLOCK, LARRY BORLAND, GLENN STREBE, MARK HATCHELL, DAVID PEAK, SUSAN FIELD AND TORIA MCGILL

STIPULATED PROTECTIVE ORDER

HONORABLE KATHLEEN M. TAFOYA JUDGE

This matter comes before the Court on the Parties’ Joint Motion for Entry of Protective Order. The Court has reviewed the Motion. Pursuant to Federal Rule of Civil Procedure 26(c), as well as Federal Rules of Evidence 502(d) and (e), the Parties have shown good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information. Therefore, IT IS ORDERED:

1. This Stipulated Protective Order (“Protective Order”) shall apply to all information, documents, electronically-stored information, and other materials disclosed, produced, exchanged, or otherwise disseminated in this case, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed, produced, or exchanged pursuant to procedures set forth in 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. As used in this Protective Order, “electronically-stored information” means any type of information that can be stored electronically, and is intended to be broad enough to cover all types of electronically stored and/or electronically transmitted information.

4. Information, documents, electronically-stored information, and/or other materials designated as “CONFIDENTIAL” (collectively, “CONFIDENTIAL material” or “CONFIDENTIAL information”) shall be information, documents, electronically-stored information, and/or other materials that are confidential such as: (a) personnel records of current or former employees of Academy School District 20 or Air Academy High School; (b) any non-public personal information, including credit or debit numbers, social security numbers, drivers’ license numbers, and bank or financial account information or password information; (c) trade secrets and commercial or financial information that is either privileged or confidential, including but not limited to policies and practices maintained by Academy School District 20 or Air Academy High School; (d) Protected Health Information; (e) non-public studies or analyses by internal or outside experts or consultants (excluding testifying experts in this case); and (f) any other material qualifying for protection under Federal Rule of Civil Procedure 26(c).

5. CONFIDENTIAL material shall not, without the consent of the party designating it as CONFIDENTIAL (the “Designating Party”) or further Order of the Court, be disclosed except that the information may be disclosed, solely for the purposes of this case to: attorneys actively working on this case; persons regularly 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; the parties, including Plaintiff and representatives of Academy School District 20; expert witnesses and consultants retained in connection with this proceeding, if any, to the extent the disclosure is necessary for preparation, trial, or at other proceedings in this case, subject to the provisions of Paragraph 6 of this Protective Order; the Court and its employees (“Court Personnel”); stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; or deponents, witnesses, or potential witnesses, subject to the provisions of Paragraph 10 of this Protective Order; other persons by written agreement of the parties.

6. Before disclosing any CONFIDENTIAL information to any consulting or testifying expert, counsel for the disclosing party or parties shall provide a copy of this Protective Order to the consulting or testifying expert, and the consulting or testifying expert shall agree to be bound to the terms of this Protective Order and shall execute a declaration identical to Exhibit 1 attached to this Protective Order.

7. CONFIDENTIAL information shall not be disclosed or used for any purpose except for the preparation, trial, and appeal of this case.

8. Information, documents, electronically-stored information, and/or other materials are designated as CONFIDENTIAL by placing or affixing (in a manner that will not interfere with their legibility) the following or other appropriate notice-“CONFIDENTIAL”-on every page containing CONFIDENTIAL information. With the exception of depositions, which are discussed below in Paragraph 10, information, documents, electronically-stored information, and/or other materials unintentionally produced without a “CONFIDENTIAL” designation or produced before the Stipulated Protective Order is issued, may be retroactively designated in the same manner.

9. Before any information is designated as “CONFIDENTIAL, ” counsel of record for the Designating Party must first review the information and make a determination, in good faith, that the information, documents, electronically-stored information, and/or other materials are confidential or otherwise are entitled to protection pursuant this Protective Order and Fed.R.Civ.P. 26(c).

10. During any deposition, CONFIDENTIAL information may be disclosed to any deponent. Before that disclosure is made, the disclosing party shall advise the deponent (as well as counsel, if any, representing the deponent) that the information about to be disclosed is subject to this Protective Order and that any further disclosure of the CONFIDENTIAL information by the deponent (or the deponent’s counsel, if any) shall constitute a violation of this Protective Order. Whenever a deposition involves the disclosure of CONFIDENTIAL information, the deposition or portions thereof shall be designated as CONFIDENTIAL and shall be subject to the provisions of this Protective Order. The designation shall be made on the record during the deposition or after ...


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