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Wood Group PSN, Inc. v. Stephens

United States District Court, D. Colorado

April 22, 2016

WOOD GROUP PSN, INC., a Nevada corporation, Plaintiff,
BRANDON STEPHENS, STUART GOBLE, and STC ENTERPRISES LLC, a Colorado limited liability company, Defendants.

N. Reid Neureiter Kimberly Berve Wheeler Trigg O’Donnell LLP., Attorneys for Plaintiff.

Brian T. Moore Jester Gibson & Moore LLP., Attorney for Brandon Stephens and STC Enterprises LLC.

Richard F. Ensor Michael Best and Friedrich, LLP., Attorney for Defendant Stuart Goble.



This Stipulated Protective Order (“Protective Order”) is entered into between Plaintiff Wood Group PSN, Inc. and Defendants Brandon Stephens, Stuart Goble, and STC Enterprises LLC (collectively, the “Parties”).

It is hereby stipulated and agreed, by and among the Parties, through their respective counsel, that the following conditions shall govern the production or disclosure of all materials produced or adduced in the course of discovery, including initial disclosures, responses to discovery requests, deposition testimony and exhibits, documents produced, and information derived directly therefrom claimed to be Confidential Information as defined below.

1. “Confidential Information” means any proprietary or confidential documentation and information containing personal or sensitive information of the supplying party that the party providing the documentation and information designates as “Confidential” in connection with this action that falls within one or more of the following categories: (a) information that reveals trade secrets; (b) research, technical, commercial or financial information that the party has maintained as confidential; (c) personal identity information; (d) income tax returns (including attached schedules and forms such as W-2 forms); (e) personnel or employment records; (f) documents that reveal commercial, financial, or personal identity information about persons who are not parties to the case; or (g) other proprietary, confidential or sensitive information. Information or documents that are available to the public may not be designated as Confidential Information.

2. In designating information or items as Confidential Information, the producing party shall make such designation only as to that information that it in good faith believes to be Confidential Information.

3. The Parties shall designate Confidential Information by marking any documents containing such information with the words “Confidential” at the time the document is produced or disclosed, or by notifying the other party in writing that such classification pertains to specific documents. An inadvertent failure to designate a document as Confidential Information at the time of production or disclosure does not, standing alone, waive the right to so designate the document; provided, however, that a failure to serve a timely Notice of Designation of deposition testimony as required by paragraph 5(a) of this Protective Order, even if inadvertent, waives any protection for deposition testimony. If a party designates a document as Confidential Information after it was initially produced, the receiving party, on notification of the designation, must make a reasonable effort to assure that the document is treated in accordance with the provisions of this Protective Order. No party shall be found to have violated this Protective Order for failing to maintain the confidentiality of material during a time when that material has not been designated Confidential Information, even where the failure to so designate was inadvertent and where the material is subsequently designated Confidential Information.

4. Confidential Information may be disclosed as follows: Any information designated as “Confidential” may be disclosed solely to the following persons:

(i) The Parties and/or their employees but only to the extent counsel determines in good faith that the employee’s assistance is reasonably necessary to the conduct of the litigation in which the information is disclosed;
(ii) Counsel of record in this action, and the attorneys and employees in the respective law firms of such counsel who have responsibility for the action;
(iii) Consultants, experts, and other witnesses, including outside technical consultants, investigators, or experts and their support staff, who are assisting or providing information to counsel and to whom it is necessary to disclose Confidential Information for the purpose of assisting in, consulting with, or providing information with respect to the matters at issue in this action, provided, however, that (1) such person is not regularly engaged in any activity that places him or her in competition with the products or services provided by the producing party; and (2) such person has signed a Consent to be Bound, attached hereto as Exhibit 1, prior to viewing or hearing any such Confidential Information. Counsel shall retain all original executed Consent to be Bound forms for their respective party. Consultants and experts do not need to be disclosed to the other party under this section provided that they meet the qualifications set forth in this section.
(iv) The Court and its personnel and court reporters, as to whom it is necessary to disclose the Confidential Information for the purpose ...

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