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Simon v. Turner

United States District Court, D. Colorado

November 28, 2016

EDDIE L. SIMON, JR., Plaintiff,
v.
ANGIE TURNER, H.S.A., and HEATHER PIKULA, Diabetic Nurse, Defendants.

          PROTECTIVE ORDER

          Craig B. Shaffer United States Magistrate Judge

         Pursuant to the Joint Stipulated Motion for Protective Order filed by the Parties, the Court hereby Orders as follows:

         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, “document” is defined as provided by Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.

         3. One who provides, serves, discloses or files any nonpublic documents or information in connection with this civil action, and who in good faith believes such documents or information are protected by a statutory, regulatory, or common law right of privacy or protection, or otherwise contain nonpublic personal, personnel, employment, private, medical, or other information implicating privacy interests, proprietary interests or safety and security concerns of either the Plaintiff, or the Defendants and their employer Corrections Corporation of America (“CCA”), may designate such documents or information as “Confidential.” The documents or information so designated shall be deemed “Confidential Material” subject to this Protective Order.

         4. Confidential Material shall be subject to the following restrictions. Confidential Material shall be used only for the limited purpose of preparing for and conducting this civil action (including any appeals), and not for any other purpose whatsoever, and shall not, without the consent of the party producing it or further Order of the Court, be disclosed in any way to anyone except those specified in this paragraph:

(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, or at other proceedings in this case; however, this does not include contract employees, other persons hired on a temporary basis, or outside agencies, organizations, or institutions;
(c) the parties and designated representatives and/or employers of the Defendants;
(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) to an insurance representative, if any, whose policies could apply to the allegations of the Complaint;
(h) witnesses in the course of deposition or trial testimony where counsel has a reasonable and good faith belief that examination with respect to the document is necessary in legitimate discovery or trial purposes in this case, and any person who is being prepared to testify where counsel has a reasonable and good faith belief that such person will be a witness in this action and that his ...

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