Free Motion for Protective Order - District Court of Colorado - Colorado

Case 1:04-cv-01233-WYD-MEH

Document 18

Filed 06/20/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-1233-WYD-OES KAREN GLOSSOP and DAVID GLOSSOP, Plaintiffs, vs. PAUL MEDINA, Defendant. _____________________________________________________________________________ DEFENDANT'S STIPULATED MOTION FOR PROTECTIVE ORDER _____________________________________________________________________________ COMES NOW the Defendants, Paul Medina, by and through their attorneys of record and enter the following Unopposed Motion for Protective Order regarding the discovery and use of raw test data in this matter. Defendant has conferred with all counsel, per local rule 7.1 and been advised there is no objection to this motion. In support of said Unopposed Motion, the parties would state as follows: Plaintiff, Karen Glossop, has asserted that he has sustained closed head injuries causing him cognitive and emotional symptoms. Certain psychologists and health care providers, specifically: Dr. Edward Cook has conducted psychological testing on the Plaintiff on which they rely in forming opinions and impressions. The parties agree that the raw data testing materials of should be provided to the Defendants' for consideration by their experts within the parameters of this case. The parties further agree that any raw data testing materials administered by any of the Defendants' retained psychologist, psychiatrists, or neurophychologists, not yet identified, should in turn be provided to Plaintiff's counsel for consideration by Plaintiff's treating physicians within the parameters of the case. Defendant requests an Order providing as follows: 1. testing. The attorneys and their experts only will be allowed to review the raw data and

Case 1:04-cv-01233-WYD-MEH

Document 18

Filed 06/20/2005

Page 2 of 3

2. The parties are ordered that they will not release or use the raw data testing materials other than within the parameters of this case, i.e., to question experts and for the limited purposes of examination at trial, and the attorneys will comply with local rule 7.3 regarding its use. 3. The parties shall make sure to return all copies of raw data and testing to the appropriate testing psychologist upon completion of the case. DATED this 20th day of June, 2005. SCHNELL & D'ANTUONO WHITE and STEELE, P.C.

By:

s/ Donald F. D'Antuono By: Donald F. D'Antuono, Esq. SCHNELL & D'ANTUONO 1660 Lincoln Street, Suite 1660 Denver, CO 80264 [email protected] Telephone: (303) 830-8800 Fax: (303) 830-8850 Attorney for Plaintiffs Karen Glossop and David Glossop

s/ John P. Craver John P. Craver White and Steele, P.C. 950 17th Street, Suite 2100 Denver, Colorado 80202 Telephone: (303) 296-2828 Fax: (303)296-3131 E-mail: [email protected] Attorney for Defendant Paul Medina

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Case 1:04-cv-01233-WYD-MEH

Document 18

Filed 06/20/2005

Page 3 of 3

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 20th day of June, 2005, I electronically file the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected]

WHITE and STEELE, P.C.

By:

s/ John P. Craver John P. Craver White and Steele, P.C. 950 17th Street, Suite 2100 Denver, Colorado 80202 Telephone: (303) 296-2828 Fax: (303)296-3131 E-mail: [email protected] Attorney for Defendant Nationwide Mutual Insurance Company

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