United States District Court, D. Colorado
DIANE K. ADAMS, Plaintiff,
TARGET CORPORATION, Defendant.
AGREED AND STIPULATED: MCDIVITT LAW FIRM, P.C. ATTORNEY FOR PLAINTIFF DIANE ADAMS
MONTGOMERY AMATUZIO DUSBABEK CHASE, LLP John R. Chase, Esq. Amanda C. Jokerst, Esq. ATTORNEYS FOR DEFENDANT TARGET STORES, A DIVISION OF TARGET CORPORATION.
STIPULATED PROTECTIVE ORDER
Hon. Kathleen M. Tafoya United States Magistrate Judge
Upon a showing of good cause in support of the entry of a protective order, under Fed.R.Civ.P. 26(c), to protect the discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, medical records, materials, and information labeled as CONFIDENTIAL by the disclosing or producing party, 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.
2. As used in this Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. Information designated “CONFIDENTIAL” shall include any documents, medical records, information or testimony, believed in good faith by a party, its counsel, or third parties producing information in connection with this litigation to contain trade secrets or other proprietary and confidential commercial and/or personal information as described or referenced in Fed.R.Civ.P. 26(c), or which are already subject to confidentiality agreements or orders separate and apart from this litigation. No CONFIDENTIAL information produced in this litigation shall be disclosed or used for any purpose except the prosecution and/or defense of this litigation.
4. CONFIDENTIAL documents, medical records, materials, and/or information (collectively “CONFIDENTIAL information”) shall not, without the consent of the party producing it or further Order of the Court, be disclosed except that such information may be disclosed to:
(a) attorneys actively working on this case;
(b) 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, at trial, or at other proceedings in this case;
(c) the parties, and the officers, directors and/or employees of the parties who have direct responsibility for assisting in the preparation and trial of the lawsuit;
(d) experts, investigators, and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
(e) the Court and its employees (“Court Personnel”), provided, however, that all court filings that attach, incorporate or disclose CONFIDENTIAL information shall be subject to D.C.COLO.LCivR 7.2 ...