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Aker v. Stonebridge Hospitality Associates, LLC

United States District Court, D. Colorado

April 28, 2016

MICHAEL AKER, Plaintiff,
v.
STONEBRIDGE HOSPITALITY ASSOCIATES, LLC, Defendant.

Charlotte N. Sweeney Ariel B. DeFazio Sweeney & Bechtold LLC Attorneys for Plaintiff

Gillian Dale Lance G. Eberhart Hall & Evans, LLC Attorneys for Defendant

STIPULATED PROTECTIVE ORDER

Nina Y. Wang Nina Wang United States Magistrate Judge

Under Rule 26(c) FED. R. CIV. P., IT IS ORDERED:

1. This Stipulated Protective Order shall apply to all documents, materials and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, depositions, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.

2. As used in this Stipulated Protective Order, “document” is defined as provided in Rule 34(a), FED. R. CIV. P. A draft or non-identical copy is a separate document within the meaning of this term.

3. Confidential documents, materials, and information (collectively, the “Confidential Information”) shall not be disclosed to any third-party, except as set forth below, or used for any purpose except the preparation and trial of this case. The duty to keep confidential information confidential survives the completion of this case.

4. The parties seek to protect certain types of confidential information. To the extent that such information cannot be filed in a redacted format, the parties agree to designate as “Confidential” documents containing the following information: (1) Social Security numbers, financial account numbers, residential addresses, and cellular phone numbers; (2) medical information regarding Plaintiff Michael Aker (“Plaintiff”) or any other individual; (3) trade secrets and confidential proprietary information of Defendant Stonebridge Hospitality Associates, LLC (“Defendant”) and its affiliates or subsidiaries; (4) personnel records involving individuals who are not parties to this case; and (5) any other material qualifying for protection under Rule 26(c), Fed. R. Civ. P.

5. A party designating documents as Confidential Information may do so by marking such material with the legend “Confidential” and only after documents are reviewed and a good faith determination made by an attorney that the documents are entitled to protection.

6. Whenever a deposition involves the disclosure of Confidential Information, the deposition or portions thereof shall be designated as “Confidential” and shall be subject to the provisions of this Stipulated Protective Order. Such designation shall be made on the record during the deposition whenever possible, but a party may designate portions of depositions as Confidential after transcription, provided written notice is promptly given to all counsel of record within thirty (30) days after notice by the court reporter of the completion of the transcript. A deposition will be designated as Confidential only after it is reviewed and a good faith determination has been made by an attorney that the deposition is entitled to protection.

7. All Confidential Information designated “Confidential” may be reviewed only by the following persons:

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 of the case, at trial, or at other proceedings in this case;
c. the parties, including Plaintiff and Defendant’s officers, management, and any advisory witnesses who are directly assisting said ...

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