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Hasler v. City of Lone Tree

United States District Court, D. Colorado

April 8, 2016

STEPHEN HASLER, Plaintiff,
v.
CITY OF LONE TREE, Defendant.

STIPULATED PROTECTIVE ORDER

Kathleen M. Tafoya United States Magistrate Judge

The Court enters the following Protective Order pursuant to Fed.R.Civ.P. 26(c).

1. In this action, certain Confidential Information has been or will be disclosed or sought during the course of discovery, including information or records concerning third-party employees of Defendant City of Lone Tree. In addition, there has been or may be questioning concerning such Confidential Information in the course of depositions and/or during trial. The Parties agree that the disclosure of such information outside the scope of this litigation could result in significant injury to one or more of the Parties’ or a third party’s business or privacy interests. The Parties have therefore entered into this Stipulation and have requested that the Court enter this Protective Order for the purpose of preventing the disclosure and use of this Confidential Information except as set forth herein.

2. 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.

3. As used herein, the term “document” means a writing, as defined in F.R.E. 1001 and includes the original or a copy of handwriting, typewriting, printing, photostating, photographing, and every other means of recording upon any tangible thing and form of communicating or representation, including letters, words, pictures, sounds, or symbols, or combinations of them.

4. “Confidential Information” means any document, record, file, portions of files, transcribed testimony, or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom that is not made available to the public and is designated by one of the Parties in the manner provided in Paragraph 5 below as containing information that is personal, proprietary or otherwise confidential and appropriate for protection under Federal Rule of Civil Procedure 26(c).

5. When Confidential Information is produced, provided or otherwise disclosed by a Party, it will be designated as such in the following manner:

a. By placing or affixing on the word “Confidential” on each page containing any Confidential Information (in a manner that will not interfere with the document’s legibility);
b. By imprinting the word “Confidential” next to or above any response to a written discovery request; and
c. With respect to transcribed testimony, by giving written notice to opposing counsel designating such portions containing Confidential Information as “Confidential” no later than 21 calendar days after receipt of the transcribed testimony or the entry of this order, whichever is later.

6. Confidential Information as identified in Paragraph 4 and 5 above 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; and
b. It shall not be communicated or disclosed by any Party, their attorney or any expert in any manner, either directly or indirectly, to anyone except for purposes of ...

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