United States District Court, D. Colorado
DONNIE L. HIGNITE, Plaintiff,
GORDON CARROLL and ARAPAHOE COUNTY BOARD OF COUNTY COMMISSIONERS, Defendants.
Mark D. Gibson, Katherine A. Nelson, Amanda R. Levin, Alison K. Toivola HOGAN LOVELLS U.S. LLP Attorneys for Plaintiff Donnie L. Hignite
Edward M. Caswall, Monica N. Kovaci Arapahoe County Attorney's Office Attorneys for Defendants Gordon Carroll and Arapahoe County Board of County Commissioners
STIPULATED PROTECTIVE ORDER
MICHAEL J. WATANABE UNITED STATES MAGISTRATE JUDGE
This matter is before the Court on the parties' stipulated motion for a protective order. The parties' motion is GRANTED and IT IS ORDERED as follows:
1. Plaintiff and Defendants will likely seek and exchange Confidential Information (as defined below in Paragraph 2) as part of their respective disclosure and discovery efforts.
2. Confidential Information means any document, file, record, oral testimony, transcribed testimony, recording, photograph, or other tangible thing, either in whole or in part and regardless as to form or format, and any disclosure or response to a discovery request, including any extract, abstract, chart, summary, note, or copy made therefrom, that contains information that is confidential or which implicates legally protected privilege or privacy interests and has been designated by one of the parties as containing Confidential Information, including, but not limited to, the following:
2.1 One or more of the parties' employment personnel file or records, including disciplinary records.
2.2 One or more of the parties' medical or healthcare records or information relating to the past, present, or future physical or mental-health condition of the parties, including psychological counseling and mental-health records. Medical or healthcare records include hut are not limited to medical bills, medical records, medical charts, test results, notes, invoices, and billing statements, and includes all notes, summaries, or oral communications that are based on or derived from the parties' medical or healthcare records.
2.3 The parties' tax or personal financial records.
2.4 Those portions of transcribed deposition or other witness testimony disclosing Confidential Information.
3. Where Confidential Information is produced, exchanged, provided, or otherwise disclosed by one party to the other party in response to any disclosure or discovery request or obligation, it must he designated as Confidential Information in the following manner:
3.1 By imprinting or stamping the word "Confidential" on the each page of any document, record, or thing produced containing Confidential Information;
3.2 By imprinting or stamping the word "Confidential" next to or above any response to a discovery request containing Confidential Information; and
3.3 With respect to any transcribed testimony containing Confidential Information, by giving written notice to opposing counsel designating such testimony, or portions thereof, as "Confidential" not later than 21 calendar days after receipt of the transcribed testimony. The parties will treat oral deposition testimony as Confidential Information upon a statement on the rec- ord by counsel designating the same unless the parties agree otherwise. Any deposition testimony designated as Confidential Information prior to the receipt of the transcribed testimony must be later identified and designated in writing as Confidential Information under this paragraph 3.3 for it to be maintained and treated as Confidential Information. Transcribed testimony or deposition exhibits ...