United States District Court, D. Colorado
Kurt Zaner, Elliot Singer, Donald H. Slavik Attorneys for Plaintiff
James Andrew Richardson Mary Quinn Cooper
James Andrew Richardson
Lee A. Mickus Attorneys for Defendant General Motors LLC
AGREED PROTECTIVE ORDER
KATHLEEN M. TAFOYA UNITED STATES 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 or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery 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, deposition testimony, and other information 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 and which contains trade secrets other confidential research, development, or commercial information. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.
4. GM may produce and designate as being “HIGHLY CONFIDENTIAL” under this Protective Order design information that is produced by GM in a three-dimensional electronic CAD data format. Plaintiff may produce and designate as being “HIGHLY CONFIDENTIAL” under this Protective Order all of Plaintiff’s psychiatric and psychological medical records. Such information designated by the parties as “HIGHLY CONFIDENTIAL” is not subject to the “sharing” provision of this Protective Order contained in Paragraph 5(h), below.
5. CONFIDENTIAL or HIGHLY 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 ...