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Rhodes v. National Collection Systems, Inc.

United States District Court, D. Colorado

February 23, 2016

AISLAND RHODES, on behalf of herself and all others similarly situated, Plaintiff,
v.
NATIONAL COLLECTION SYSTEMS, INC., Defendant.

Michael L. Greenwald Greenwald Davidson Radbil PLLC Attorney for Plaintiff

Charity A. Olson Olson Law Group Attorney for Defendant

PROTECTIVE ORDER

Hon. Kathleen M, Tafoya United States Magistrate Judge

Pursuant to stipulation of the parties and in accordance with the provisions of Fed.R.Civ.P. 26(c), IT IS HEREBY ORDERED THAT:

1. Confidential information must be designated by stamping “CONFIDENTIAL” on the copies of the document produced. Stamping “CONFIDENTIAL” on the cover of any multipage document will designate all pages of the document as Confidential Material, unless otherwise stated by the producing party. In the case of deposition testimony, a party may request at the time a question is asked, or at the end of the deposition, that any portion of the deposition transcript be designated confidential. A party may designate any portion of a deposition as “CONFIDENTIAL” after transcription of the deposition, provided that written notice of the designation is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript.

2. By designating a document, thing, material, testimony or other information derived therefrom as “Confidential, ” under the terms of this order, the designating party is certifying that there is a good faith basis both in law and in fact for the designation within the meaning of Federal Rule of Civil Procedure 26(g).

3. Material designated as Confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as confidential (hereinafter “Confidential Material”) shall be used only for the purpose of the prosecution, defense, or settlement of this action, and for no other purpose.

4. Information may be designated “CONFIDENTIAL” only after counsel for the party making the designation has reviewed, or heard, the information and believes, in good faith, that the information is confidential or otherwise entitled to protection.

5. The confidential information discussed in ¶ 1 above, and all tangible embodiments thereof, all copies thereof, the substance thereof, and all information contained therein (hereinafter collectively referred to as “Confidential Material”):

(a) shall not be disclosed or distributed by counsel, or any other person receiving, viewing or hearing the Confidential Material (“Receiving Person”) to any person other than to (1) attorneys actively working on or supervising the work in this case; (2) 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; (3) the parties; (4) 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; (5) the Court and its employees (“Court Personnel”); (6) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action; and (7) other persons by written agreement of the parties.
(b) shall be filed with the Court, should filing be desired or required, in accordance with D.C.Colo.LCivR 7.2; and,
(c) shall not be disclosed to any consulting or testifying expert unless the party making the disclosure follows the provisions of ¶ 7 of this Protective Order.

6. By agreeing to the limited disclosure permitted under this Protective Order, no party waives its claim that Confidential Material is confidential. All parties agree that a disclosure in accordance with this Protective Order does not constitute a waiver of a party’s claim or position that the information so disclosed is confidential. All parties agree that no party will contend that the failure to mark a particular document “CONFIDENTIAL” or to designate any portion or a deposition as “CONFIDENTIAL” constitutes a waiver of the other party’s position, if any, that a document or a portion of a deposition contains Confidential Material, unless the party seeking to assert waiver first notifies the other party in writing of its intention to claim waiver and gives the other party three (3) business days within which to designate as confidential the document or portion or deposition transcript at issue.

7. Before disclosing any Confidential Material to any consulting or testifying expert, counsel for the disclosing party or parties shall have the consulting or testifying expert read this Protective Order and shall explain the contents of this Protective Order to that person. The consulting or testifying expert shall agree to be bound to the terms of this ...


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