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Mueller v. Swift

United States District Court, D. Colorado

April 14, 2016

DAVID MUELLER Plaintiff,
v.
TAYLOR SWIFT; FRANK BELL ANDREA SWIFT a/k/a ANDREA FINLAY; SCOTT SWIFT; and JOHN DOES 1-5 Defendants.

PROTECTIVE ORDER

Hon. Kristin L. Mix U.S. Magistrate Judge

1. PURPOSE AND LIMITATIONS

The parties agree that disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties agree to be bound by the following Protective Order ("Order") in this action.

2. DEFINITIONS

2.1 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

2.2 Party: any party to this action and their agents and representatives, consultants, retained experts, and Outside Counsel of Record (and their support staffs).

2.3 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.

2.4 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

2.5 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action, (2) is not a past or current employee of a Party or of a Party's competitor, and (3) at the time of retention, is not anticipated to become an employee of a Party or of a Party's competitor.

2.7 "CONFIDENTIAL" Information or Items: Regardless of how the information is generated, stored or maintained: (a) all material designated "Confidential" hereunder and/or (b) sensitive information including sensitive personal information and sensitive business information kept confidential in the ordinary course of business, such as (i) nonpublic, private information, (ii) financial data, and (iii) business and marketing plans, public disclosure of which could result in harm to the Producing Party. This section applies to all information that qualifies for protection under Federal Rule of Civil Procedure 26(c).

3. SCOPE

The protections conferred by this agreement cover not only Confidential material (as defined above), but also: (1) any information copied or extracted from Confidential material; (2) all copies, excerpts, summaries, or compilations of Confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Confidential material. The parties may seek all appropriate relief from the Court to enforce protection of Confidential material.

4. DURATION

The confidentiality obligations imposed by this Order shall remain in effect in perpetuity, unless and until a Designating Party agrees otherwise in writing, or a court order otherwise directs, after ...


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