United States District Court, D. Colorado
MICHAEL K. GRAY and JERRY PARKISON, Plaintiff,
THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF ARAPAHOE COUNTY, Defendant.
ROSEMARY ORSINI BERENBAUM WEINSHIENK PC ATTORNEY FOR PLAINTIFF
DAVID R. DEMURO SHELBY A. FELTON VAUGHAN & DEMURO, P.C. ATTORNEYS FOR DEFENDANTS
STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION
KRISTEN L. MILK U.S. MAGISTRATE JUDGE
The parties, by and through their respective counsel, stipulate to the entry of this Protective Order Concerning Confidential Information, as follows:
1. This Protective Order applies 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.
2. As used in this Protective Order, the term "document" has the meaning set forth in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.
3. Any party may, at any time, designate a served, disclosed, or filed document "Confidential" if, after review by a lawyer, the lawyer certifies that the designation as "Confidential" is based on a good faith belief that the document contains nonpublic personal, personnel, employment, financial and/or tax records, medical, or other information implicating privacy or proprietary interests of either the plaintiffs, the defendants or a third party. The documents so designated will be deemed "Confidential Material" subject to this Protective Order.
4. In the event Electronically Stored Information ("ESI") is disclosed or discovered in the course of this litigation, including, but not limited to ESI provided in a native format on hard disks or other magnetic data storage disks, removable disks and/or drives, portions thereof, or digital images of data storage disks or drives, such information may be designated as CONFIDENTIAL in a written communication or in an electronic mail message to the non-producing party or parties.
5. Confidential Material is subject to the following restrictions. Confidential Material may be used only for the limited purpose of preparing for and conducting this civil action (including any appeals), and must not be disclosed in any way to anyone except:
(a) attorneys actively working on this case;
(b) persons regularly employed or associated with the attorneys actively working on this case;
(c) the parties, including Plaintiffs' and Defendant's designated representatives and insurers;
(d) stenographic reporters who are engaged in proceedings ...