United States District Court, D. Colorado
CraigB. Shaffer United States Magistrate Judge
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:
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.
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.
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.
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
(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
(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
(e) the Court and its employees (“Court
(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.
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 ...