Free Protective Order - District Court of Colorado - Colorado

Case 1:04-cv-00538-ZLW-CBS

Document 58

Filed 06/29/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil ActionNo.: 04-Z-0S38 (CBS)
MARK I...:TEAGUE,

Plaintiff.

v.
TOWN OF DEL NORTE,COLORADO,

Defendant. STIPULATED ?ROTECTIVE ORDER

.

.
The parties have disclosed documentswhich necessitatethe useof a protective

The panies, hereto, Plaintiff acting pro se and Defendant by and through its attorneys, h. respectivelymove this Court to enter the following ProtectiveOrder:

order because they .concern private personnel and financial matters and inforDlation regarding individuals who are not panies to the lawsuit that are confidential. AU documents subjectto this

Protective Order will contain a stamp which reads "Subject to ProtectiveOrder" or
"Confidential. tt

2.

The parties will make available to the other parties documentssubject to this

Order. The partiesagreethat the materialwill only be usedfor purposes this litigationand of
\\ill not be disseminated beyond the attorneys,parties.membersof the attorneys' staff. or expert

witnesses, the absence a stipulationamongthe partiesor orderof this Court. The parties in of
and/or attorneysfor all parties hereby agreeto advise their staff, clients and expen witnessesof the terms of the ProtectiveOrder.

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3.

To the extent any documentsproducedunder this Protective Order are filed with

the Court, the filing party must follow the procedures forth in D,C.COLO.LCivR 7.3, set 4
.~.

Upon tennination of this litigation, all originals and copies of the docwnents

produced by the parties under this Protective Order shall be returned promptly to the producing party. Further, each party and/or their counselwill notify any expen \vitnesses the existence of

of thisprotective order
s.

All working papers otherdocumentS the possession. or in custody controlof or

the panies and/or parties' counselrelating to the infonnation derived from docwnentS coveredby the Protective Order shall be promptly destroyedor sealedand kept confidential by eachparty's

and/ortheircounsel.
6.

"Nothingcontained this Protective in Ordershall be deemed imply that any of to

the documentsproduced are relevant to the issuesinvolved in this case,nor that they are not subject to someother objection or privilege

7.

To the extent that these materialsare the subject of a depositionin this case,any

documentsmade an exhibit to a pleading filed with the Court and the portion of the deposition attachedas an exhibit to a pleading filed with the Coun in which the matter is discussed shall be

sealed shallcarrythe notation"Confidential. This document subject protective and is to order
and may not be examinedor copied except in compliancewith such order.'

8.

The parties agreethat disseminationof thesedocumentsare limited by the tenDS

of this ProtectiveOrder.
9.

The partiesagreethat prior to designatingdocumentsas Confidential Infonnation,

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the party designatingthe document will review the infonnation and only designateif there is a good faith belief that the information is confidential or otherwiseentitled to protection. 10.
..:.~

A party may object to the designationof particular Confidential Information by

giving written notice to the party designatingthe disputed infonnation. The written notice shall

identify the infonnationto which the objectionis made. If the partiescannotresolvethe
objection within (10) businessdays after the time the notice is received,it shall be the obligation of the party designating the information as "confidential" to file an appropriate motion

requesting the court determine that whetherthe disputedinformationshouldbe subjectto the
terms of this ProtectiveOrder. If such a motion is filed within 20 businessdaysof the notice,the disputed infonnation shall be treatedas confidential underthe tenDS this ProtectiveOrder until of the Court rules ~n the motion. If the designatingparty fails to file such a motion within the prescribedtime, the disputed information shall lose its designationas confidential and shall not thereafterbe treatedas confidential in accordance with this Protective Order. In connection\a.ith a motion filed under this provision, the party designatingthe information as Confidential shall bear the burden of establishingthat good causeexists for the disputed infonnation to be treated as ConfidentiaJ 1

The partiesacknowledge that the Court retainsthe right to alter, amend,or

otherwise changethis Protective Order The parties,agree,however, that the Order shall remain in effect until further notice is receivedfrom the Court.

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This Protective Orderis herebyexecuted made Orderof this Courtthis~y and an

o~

~.

2005.

BY THE COURT:

c:-ii:!~l)S.r' ~

'$'tr ~ ~ ~.ad-&CNArnAN, BREMER, DUMM &. MYERS

~

"/1

1:JJ,~~'

. 1"(\j)l.t!\aJ{\Ol.n.l~)'.k..)-J. Andrew Nathan, Esq. Mami Nathan Kloster 3900 E. Mexico Ave.. Suite 1000 Denver, CO 80210

Mark eague-(Poro Se 254 SchlauchRd. Mohaton, PA 19540

H;\CASESlc;nca jaa\P~III'#.-.i"

0.48.-

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