United States District Court, D. Colorado
PLAINTIFF'S PROPOSED PROTECTIVE ORDER
NINA Y. WANG UNITED STATES MAGISTRATE JUDGE.
The parties, through their respective counsel, hereby agree to the following Stipulated Protective Order and request that it be entered as an Order of the Court.
Upon a showing of good cause in support of the entry of a protective order to protect the disclosure and discovery of confidential and security-sensitive documents and information in this case, IT IS ORDERED:
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, responses to requests for production of documents, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure (collectively, "Disclosed Information").
2. As used in this Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a).
3. Any party providing Disclosed Information may designate such as CONFIDENTIAL. Any Disclosed Information designated “CONFIDENTIAL” shall be that in which a person or entity has (a) a statutory, regulatory, or common law right of privacy and the person or entity has not consented to disclosure of the private information; or (b) a vested interest in protecting against dissemination or disclosure of the Disclosed Information based on it being proprietary or non-public business information relating to operational strategies, policies, plans, corporate structure, prison safety and security, and similar information treated or considered by a Party, whether by policy or practice, to be proprietary. Disclosed Information designated as CONFIDENTIAL shall not be disclosed or used for any purpose except the preparation and trial of this case. Third-parties providing any Disclosed Information may designate such as CONFIDENTIAL per this Protective Order, and any party to this Protective Order may designate such as CONFIDENTIAL per this Protective Order.
4. CONFIDENTIAL documents, materials, and/or information (collectively “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;
b. attorneys actively working on this case;
c. persons regularly employed 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;
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 ...