United States District Court, D. Colorado
Craig B. Shaffer United States Magistrate Judge
Pursuant to the Joint Motion for Entry of Protective Order filed by the parties, the Court hereby orders as follows:
1. This Protective Order applies to all documents, materials, and information, including but not limited to documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information that is disclosed in this matter pursuant to (a) the disclosure or discovery duties created by the Federal Rules of Civil Procedure, (b) agreement of the parties, and (c) orders of the Court.
2. As used in this Protective Order, “document” is defined as provided in Federal Rule of Civil Procedure 34(a). A draft or nonidentical copy is a separate document within the meaning of this term.
3. One who provides, serves, discloses, or files any nonpublic documents or information in connection with this action, and who in good faith believes any such document or information contains nonpublic personal, private, financial, social-services, or proprietary information; trade secrets or other competitively sensitive information; other confidential research, development, or commercial information; or other information implicating privacy interests or proprietary interests of either Plaintiff or Defendant, or of any other person, may designate such documents or information as “Confidential.” The documents or information so designated shall be deemed “Confidential Material” subject to this Protective Order.
4. Confidential Material shall be used only for the limited purpose of preparing for and conducting this civil action (including any motions, hearings, trials, or appeals), and not for any other purpose whatsoever, and shall not, without the consent of the party producing it or further order of the Court, be disclosed in any way to anyone except those specified in this paragraph:
a. attorneys involved with the litigation;
b. persons regularly employed by, or contracted with, or associated with the attorneys involved with the litigation whose assistance is deemed required by said attorneys in the preparation for trial or other proceedings in this case;
c. the parties and designated representatives of Defendant, as well as their insurers and reinsurers;
d. deponents, consultants, and witnesses (both lay and expert) who execute the attached Exhibit A;
e. the Court and its employees;
f. stenographic reporters and videographers who are engaged in proceedings incident to the conduct of this action;
g. copying or scanning services and their employees who will, or who may be asked to work with counsel to reproduce, organize, image, or otherwise work ...