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Woodstock v. Shaffer

United States District Court, D. Colorado

February 16, 2016

JONATHAN LANE WOODSTOCK, Plaintiff
v.
LT. S. SHAFFER, BRET RICKARD, CHAPLAIN, CAPTAIN PALMER, AND S. JONES, Defendant

Jeannine Sue Haag LARIMER COUNTY ATTORNEY’S OFFICE, Attorneys for Defendants S. Shaffer, Lt. and Defendant Palmer, Captain.

Bethany Gorlin SNELL & WILMER Tabor Center, Attorney for Defendant Bret Rickard, Chaplain.

Andrew B. Clauss Chris W. Brophy Nicole Marie Black LEWIS BRISBOIS BISGAARD & SMITH LLP., Attorneys for Defendant S. [Shad] Jones.

PROTECTIVE ORDER

THIS MATTER comes before the Court on Defendant S. Jones’s Motion for Entry of Protective Order (the “Motion”). The Court having reviewed the Motion, the record, and the law, finds that the Motion is well-taken and hereby GRANTS the relief requested. It is therefore ORDERED that the following is made an Order of the Court:

PROTECTIVE ORDER

1) “Confidential Information” means any document, file, portions of files, transcribed testimony, or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom - not made available to the public - and designated by one of the Parties in the manner provided in paragraph 3 below as containing: information regarding, or created pursuant to, certain policies, procedures, and operations to which Defendants have proprietary, security, and other confidential interests. Disclosure of these documents outside the scope of the litigation would cause undue burden on Defendants as well as injury to their privacy interests considering Defendants’ involvement with the operation of a state criminal correctional facility.

2) “Counsel” refers to any Party’s counsel of record as well as self-represented, or pro se litigants, in the above captioned lawsuit.

3) Where Confidential Information is produced, provided or otherwise disclosed by Defendants in response to any discovery request, it will be designated in the following manner:

a) By imprinting the word “Confidential” on the first page or cover of any document produced;
b) By imprinting the word “Confidential” next to or above any response to a discovery request; and
c) With respect to transcribed testimony, by giving written notice to opposing counsel designating such portions as “Confidential” no later than ten calendar days after receipt of the transcribed testimony.

4) All Confidential Information provided by Defendants in response to a discovery request or transcribed testimony shall be subject to the following restrictions:

a) It shall be used only for the purpose of this litigation and not for any business or other purpose whatsoever;
b) It shall not be communicated or disclosed by any Party’s counsel or a Party in any manner, either directly or indirectly, to anyone except for purposes of this case and unless an ...

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