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Delgado v. Correct Care Solutions, LLC

United States District Court, D. Colorado

February 11, 2016

ESTATE OF JENNIFER LOBATO, by and through its personal representative Paul Montoya; PAUL MONTOYA, individually; ANGELICA DELGADO; A.Z., a minor, by and through his father, Paul Montoya; J.M., a minor, by and through her father, Paul Montoya; V.M., a minor, by and through her father, Paul Montoya; L.F., a minor, by and through his father, Luciano Frasquez; and A.F., a minor, by and through his father, Luciano Frasquez, Plaintiffs,
v.
CORRECT CARE SOLUTIONS, LLC; CORRECTIONAL HEALTHCARE COMPANIES, INC.; CORRECTIONAL HEALTHCARE PHYSICIANS, P.C.; THE BOARD OF COUNTY COMMISSIONERS FOR JEFFERSON COUNTY COLORAD; a government entity JEFF SHRADER, in his individual and official capacity as Jefferson county sheriff only; DEPUTY SHERRY GRAY, in her individual capacity; DEPUTY ASHLEY ROBBINS, in her individual capacity; DEPUTY JOHN GARCIA, in his individual capacity; DEPUTY ASHLEY CURTIS, in her individual capacity; DEPUTY CARRIE SPAICH “HATHC”, in her individual capacity; DEPUTY LARRY WHEELER, in his individual capacity; DEPUTY DANIEL LONGSHORE, in her individual capacity; DEPUTY RACHEL OBERMEYER, in her individual capacity; BRYAN F MUSCUTT, in his individual capacity; JESSICA ROMERO, in her individual capacity; CAROLINE RYAN, in her individual capacity; BRIANNA WHINNERY, in her individual capacity;ESME ZIEGELMAN, in her individual capacity; Defendants.

STIPULATED PROTECTIVE ORDER

Kathleen M. Tafoya United States Magistrate Judge

Pursuant to Fed.R.Civ.P. 26(c), upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:

1. This Stipulated 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 Stipulated 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 and implicates common law and statutory privacy interests or security interests of: (a) Plaintiffs Estate of Jennifer Lobato, Paul Montoya, Angelica Delgado, A.Z., J.M., V.M. or L.F.; or (b) Defendants the Board of County Commissioners of the County for Jefferson County, Colorado, Deputy Sherry Gray, Deputy Ashley Robbins, Deputy John Garcia, Deputy Ashley Curtis, Deputy Carrie Spaich (“Hatch”), Deputy Larry Wheeler, Deputy Daniel Longshore, Deputy Rachel Obermeyer, Bryan F Muscutt, Jessica Romero, Caroline Ryan, Brianna Whinnery, Esme Ziegelman, including confidential, security-sensitive, proprietary, trade secret, financial, or personal information. Any information designated by a party as CONFIDENTIAL must first be reviewed by a lawyer 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.” Gillard v. Boulder Valley Sch. Dist., 196 F.R.D. 382, 386 (D. Colo. 2000). CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

4. 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. the parties’ attorneys;
b. persons regularly employed or associated with the parties’ attorneys that are actively working on the case whose assistance is required by said attorneys in the preparation of the case, at trial, or at other proceedings in this case;
c the parties, including designated representatives for the Plaintiffs and Defendants;
d. expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for 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 conduct of this action;
g. deponents, witnesses, or potential witnesses; and
h. other persons by written agreement of ...

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