United States District Court, D. Colorado
ALEJANDRO MENOCAL, MARCOS BRAMBILA, GRISEL XAHUENTITLA, HUGO HERNANDEZ, LOURDES ARGUETA, JESUS GAYTAN, OLGA ALEXAKLlNA, DAGOBERTO VIZGUERRA, and DEMETRIO VALERGA, on their own behalf and on behalf of all others similarly situated, Plaintiffs,
THE GEO GROUP, INC., Defendant.
R. Andrew Free Attorneys for Plaintiffs
Shelby A. Felton Attorneys for Defendant
STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
John L. Kane Senior U.S. District Court Judge
IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, that:
1. The parties desire to maintain the confidentiality of certain of the documents produced in this case, including to protect the privacy of individuals;
2. Therefore, in order to protect against the disclosure of sensitive and confidential information, while at the same time, observing the requirements of Rule 26 of the Federal Rules of Civil Procedure, and to permit the parties to discover and, if otherwise admissible, make reasonable use at trial and other matters in this litigation information relevant to the subject matter of this case, the parties, by and through their respective counsel, hereby stipulate to the entry of this Protective Order and agree as follows, and respectfully request that the Court so order:
1. This Protective Order applies 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, the term “document” has the meaning set forth in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. The designation “Confidential” means the information shall be used solely for the purposes of this litigation, and shall not be used for any other purpose or suit, nor published to the general public in any form, or used for any business or commercial purpose.
4. Any party may, at any time, designate a served, disclosed, or filed document “Confidential” if, after review by an attorney, the attorney certifies that the designation as “Confidential” is based on a good faith belief that the document contains nonpublic personal, personnel, employment, financial and/or tax records, medical, or other information implicating privacy or proprietary interests of either the Plaintiffs, the Defendant or a third party (including any documents and information that are subject to the Privacy Act). The documents so designated will be deemed “Confidential Material” subject to this Protective Order. Any confidential designation that is inadvertently omitted following the entry of this Protective Order will not constitute a waiver of confidentiality, and may be corrected by written notification to the parties.
5. No copies of “Confidential” material shall be made except to the extent necessary for the litigation of this action and the parties preparation of this action for trial (including any appeals).
6. “Confidential” information shall be handled as follows:
(a) Information designated as “Confidential” shall not be disclosed to the public in any form by the parties or their respective counsel, nor disclosed to any other ...