United States District Court, D. Colorado
B. SHAFFER, Magistrate Judge.
to the Joint Stipulated Motion for Protective Order filed by
the parties, the Court hereby Orders as follows:
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.
used in this Protective Order, "document" is
defined as provided by Fed.R.Civ.P. 34(a). A draft or
non-identical copy is a separate document within the meaning
of this term.
who provides, serves, discloses or files any nonpublic
documents or information in connection with this civil
action, and who in good faith believes such documents or
information are protected by a statutory, regulatory, or
common law right of privacy or protection, or otherwise
contain nonpublic personal, personnel, employment, private,
medical, or other information implicating privacy interests,
proprietary interests or safety and security concerns of
either the Plaintiff, Jason Brooks, or any of the Defendants
may designate such documents or information as
"Confidential." The documents or information so
designated shall be deemed "Confidential Material"
subject to this Protective Order.
Confidential Material shall be subject to the following
restrictions. Confidential Material shall be used only for
the limited purpose of preparing for and conducting this
civil action (including any appeals), and not for any other
purpose whatsoever, and shall not, without the consent of the
party producing it or further Order of the Court, be
disclosed in any way to anyone except those specified in this
attorneys actively working on this case;
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, or at other
proceedings in this case;
parties and designated representatives of the Defendants;
expert witnesses and consultants retained in connection with
this proceeding, to the extent such disclosure is necessary
for preparation, trial or other proceedings in this case;
Court and its employees ("Court Personnel");
stenographic reporters who are engaged in proceedings
necessarily incident to the conduct of this action;
deponents, witnesses, or potential witnesses who execute the
attached Exhibit A;
other persons by written agreement of the parties who ...