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Jara v. Standard Parking Corp.

United States District Court, D. Colorado

February 1, 2016

ABDULLAHIHAMU JARA, Plaintiff,
v.
STANDARD PARKING CORPORATION and UNION TEAMSTER LOCAL 455, Defendants.

PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION

The court hereby issues this Protective Order Concerning Confidential Information, 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 that are confidential and are designated as "CONFIDENTIAL" pursuant to the terms of this Protective Order.

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. "CONFIDENTIAL" information covered under the terms of this protective order shall include documents, materials and/or information produced by either Abdullahi Hamu Jara ("Plaintiff), or SP Plus Corporation and Union Teamster Local 455 (collectively "Defendants"), or any of Plaintiffs or Defendants' agents or representatives, when designated as "CONFIDENTIAL" as provided herein, that include proprietary and/or confidential information not publicly available, and/or which implicate a privilege or legitimate privacy interest.

As a condition of designating documents "CONFIDENTIAL, " the documents must be reviewed by plaintiff pro se or a lawyer of the designating party who will certify that the designation as "CONFIDENTIAL" is based on a good faith belief that the information is confidential or otherwise entitled to protection.

4. CONFIDENTIAL information shall not be disclosed or used for any purpose except in discovery and in the preparation and trial of this case.

5. 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 working on this case;
(b) persons regularly employed or associated with the attorneys working on the case whose assistance is deemed required by said attorneys in discovery, the preparation for trial, at trial, or other proceedings in this case;
(c) the parties and designated representatives for the entity defendants;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is deemed necessary for discovery, 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 ...

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