United States District Court, D. Colorado
Richard P. Matsch, Senior District Judge
This matter comes before the Court on the parties' Joint Motion for Entry of Protective Order. (ECF No. 16). The Court has reviewed that Motion. The parties have shown good cause in support of the entry of a protective order to protect the discovery and dissemination of confidential information. Therefore, IT IS ORDERED:
1. This Protective Order shall apply to all confidential documents, materials, and information, produced, given, or exchanged by and among the parties and non-parties to this action including, without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, deposition exhibits, and any other confidential 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. As used in this Protective Order, "Designating Party" is defined as any party who has designated documents, materials, or information as "CONFIDENTIAL."
4. Information designated as "CONFIDENTIAL" shall be information that implicates common law privacy interest, statutory privacy interest, or other confidentiality interests such as: (a) certain designated portions of the Plaintiffs personnel records and the relevant personnel records of the Defendants' current or former employees or applicants for employment; (b) Defendants' trade secrets; (c) privileged or confidential commercial information; and (d) privileged or confidential fmancial information. "CONFIDENTIAL" information shall not be disclosed for any purpose except for the preparation and trial of this case and as prescribed by law.
5. "CONFIDENTIAL" documents, materials, or information (collectively "CONFIDENTIAL information") shall not, without the consent of the designated party 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 and the designated representatives for the parties;
d. Expert witnesses and consultants retained in coimection with this proceeding, to the extent that such disclosure is necessary for preparation, trial or other proceedings in this case;
e. The Court and its employees ("Court Personnel");
f. Stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
g. Deponents, witnesses or potential witnesses likely to have knowledge or information related to the subject matter of the confidential ...