United States District Court, D. Colorado
Scott F. Reese, P.C., Attorney for Plaintiff.
Melisa Panagakos, Assistant Attorney General, Civil Litigation and Employment Law Section, Attorneys for Defendants Colorado Department of Youth Corrections.
STIPULATED PROTECTIVE ORDER
MICHAEL J. WATANABE, U.S. MAGISTRATE JUDGE.
Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of Confidential Information, IT IS HEREBY ORDERED:
1. This Protective Order shall apply to all documents, materials, and information appropriately designated as Confidential as outlined in paragraphs 3 through 7 herein. This includes without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information or documents disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.
2. As used in this 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, trade secret, or implicates common law and/or statutory privacy interests of current or former youth residents, employees, representatives or agents of Colorado Department of Human Services, Division of Youth Corrections ("DHS") including but not limited to Plaintiff Shantell Honest, as well as third parties who have had contact with the Division of Youth Corrections. Designation of information as Confidential shall not affect its discoverability. Confidential Information shall be used for the sole, strict and limited purpose of the preparation and trial of this action and shall not be used for any other purpose.
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) attorneys actively working on this case;
(b) 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;
(c) the Parties, including designated representatives for DHS;
(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/or its employees ("Court Personnel");
(f) stenographic reporters who are engaged in proceedings necessarily incident to the ...