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Ambrosio v. Dougals County School District

United States District Court, D. Colorado

November 28, 2016

DIANE AMBROSIO, SUSAN ARCHIBALD AND WILLIAM GREGG, Plaintiff,
v.
DOUGLAS COUNTY SCHOOL DISTRICT, RE-1, Defendant.

          PROTECTIVE ORDER

          CraigB. Shaffer United States Magistrate Judge

         This matter comes before the Court on the parties' Stipulated Motion for Entry of Protective Order. The Court has reviewed that Motion. The Motion is meritorious and acceptable. Therefore, IT IS ORDERED:

         1. This Protective Order shall apply 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 definition of “document” will be interpreted in accordance with Fed.R.Civ.P. 34(a)(1). A draft or non-identical copy is a separate document within the meaning of this term.

         3. Information designated “CONFIDENTIAL” shall be information that is confidential and implicates common law and statutory privacy interests such as: (a) financial records of Plaintiffs; (b) financial records of other School District employees; (c) information constituting education records or containing student personally identifiable information as defined by the Family Educational Rights and Privacy Act of 1974, 20 U.S.C. § 1232g; and (d) other confidential information relating to the School District, its students, and its employees. CONFIDENTIAL information shall not be disclosed or used for any purpose except the preparation and trial of this case.

         4. CONFIDENTIAL documents, materials, and/or information (collectively “CONFIDENTIAL information”) shall be used solely for the purpose of this action, and shall not, without the consent of the party producing it or further Order of the Court, be used, transferred, disclosed or communicated in any way, 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, including designated representatives for Defendant;
(d) expert witnesses 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”);
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
(g) deponents, witnesses, or potential witnesses; and (h) other persons by written agreement of the parties.

         5. Prior to disclosing any CONFIDENTIAL information to any person listed above (other than counsel, persons employed by counsel, Court Personnel and stenographic reporters), counsel shall provide such person with a copy of this Protective Order and obtain from such person an executed “Written Assurance” in the form attached hereto as Exhibit A. All such written assurances shall be retained by counsel ...


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