United States District Court, D. Colorado
Alison Ruttenberg, Attorney for Plaintiffs.
Eric M. Ziporin Senter Goldfarb & Rice, LLC., DJ Goldfarb Senter Goldfarb & Rice, LLC., Attorneys for Defendants Josh Vaughn, Michael Deedon, Jeremy Ehrlich and Heidi Walts.
Ryan Winter Hall & Evans, LLC., Andrew P. Reitman Hall & Evans, LLC., Attorneys for Defendants Drew Klescewski, Nichole Backus, H&M Hernes and Marritz.
NINA Y WANG UNITED STATES MAGISTRATE JUDGE.
1. The Parties anticipate seeking Confidential Information during discovery and that there will be questioning concerning Confidential Information in the course of depositions and other proceedings in this action. The Parties assert that the disclosure of such information outside the scope of this litigation could result in significant injury to one or more of the Parties’ business, security or privacy interests.
2. “Confidential Information” means any document, file, portions of files, transcribed testimony, or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom that contains information that is confidential and implicates common law and/or statutory privilege interests, statutory privacy interests, and/or designated by one of the Parties in the manner provided in paragraph 4 below as containing Confidential Information, including, but not limited to:
a. the Parties’ medical and mental health records,
b. the Parties’ employment information, including any IAB files on any Defendant.
c. any documents containing confidential information relating to third parties.
c. any documents containing proprietary information including, but not limited to, trade secrets, employment policies and security protocols.
3. Where Confidential Information is produced, provided or otherwise disclosed by a Party in response to any discovery request, it will be designated in the following manner:
a. By imprinting the word “Confidential” on the first page or cover of any document produced;
b. By imprinting the word “Confidential” next to or above any response to a discovery request; and
c. With respect to transcribed testimony, by giving written notice to opposing counsel designating such portions as “Confidential” no later than ten (10) calendar ...