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Pugh v. Staffing

United States District Court, D. Colorado

March 1, 2016

PATTI PUGH, individual, Plaintiff,
v.
ELWOOD STAFFING D/B/A SOS EMPLOYMENT GROUP, A/K/A SOS STAFFING SERVICES, an Indiana corporation, Defendant.

Mark J. Berumen Kristen Kavan Berumen Law Firm, P.C. Attorneys for the Plaintiff

Roger G. Trim Raul Chacon, Jr. Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Attorneys for the Defendant

STIPULATION AND PROTECTIVE ORDER

JOHN L. KANE, SENIOR JUDGE

Each Party and each Counsel of Record stipulate and move the Court for a Protective Order pursuant to Rule 26(c) of the Federal Rules of Civil Procedure concerning the treatment of Confidential Information (as hereinafter defined), and, as grounds therefor, state as follows:

1. In this action, at least one of the Parties has sought and/or is seeking Confidential Information (as defined in paragraph 2 below). The Parties also anticipate seeking additional Confidential Information during discovery and that there will be questioning concerning Confidential Information in the course of depositions. The Parties assert the disclosure of such information outside the scope of this litigation could result in significant injury to one or more of the Parties’ business or privacy interests. The Parties have entered into this Stipulation and request the Court enter the within Protective Order for the purpose of preventing the disclosure and use of Confidential Information except as set forth herein.

2. “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: (a) personnel information concerning current and former employees of Defendant Elwood Staffing Services, Inc., incorrectly identified as Elwood Staffing d/b/a SOS Employment Group, a/k/a SOS Staffing Services (“Defendant” or “Elwood Staffing”), to the extent that such information implicates privacy interests and is not generally known to the public; (b) proprietary business information of the Defendant; (c) information containing industry trade secrets; and (d) information relating to Plaintiff concerning personal and confidential matters not generally known to the public, such as, but not limited to, income information, medical information, and information regarding contacting prospective employers.

3. Where Confidential Information is produced, provided or otherwise disclosed by a Party 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 a Party 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 affidavit in the form of Exhibit A has been signed.

5. The Parties further anticipate seeking Confidential - Attorneys’ Eyes Only Information (as defined by Paragraph 6 below) during discovery and that there will be questioning concerning Confidential - Attorneys’ Eyes Only Information in the course of depositions. The Parties’ assert the disclosure of such information outside the scope of this litigation could result in significant injury to one or more of the Parties’ business or privacy interests.

6. “Confidential - Attorneys’ Eyes Only 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 a manner provided in paragraph 7 below as containing information relating to highly sensitive personal and confidential matters not generally known to the public.

7. Where Confidential - Attorneys’ Eyes Only Information is produced, provided or otherwise disclosed by a Party in response to any discovery request, it ...


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