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

Case 1:03-cv-01959-MSK-PAC

Document 227

Filed 07/25/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-01959-MSK-PAC AHMED M. AJAJ, Plaintiff, v. UNITED STATES OF AMERICA, ROBERT A. HOOD, JAMES BURRELL, DAVID DUNCAN, C. CHESTER, and J.C. ZUERCHER, Defendants.

STIPULATED MOTION FOR ENTRY OF PROTECTIVE ORDER

COME NOW Plaintiff Ahmed Ajaj ("Plaintiff"), by and through his counsel, Carmen Reilly and John Riley, and Defendants United States of America, Robert A. Hood, James Burrell, David Duncan, C. Chester, and J.C. Zuercher, by and through United States Attorney for the District of Colorado William J. Leone and Assistant United States Attorneys Amanda Rocque and Elizabeth Weishaupl, and jointly move for the entry of a Protective Order restricting the production of certain documents to Plaintiff for purposes of the above-captioned action. In support of this motion, the parties state as follows: 1. On May 22, 2005, Plaintiff served Defendants with a copy of Plaintiff's First Set

of Interrogatories and Requests for Production. 2. The Bureau of Prisons has identified information that is responsive to Plaintiff's 1

Case 1:03-cv-01959-MSK-PAC

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Filed 07/25/2006

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discovery requests. However, some of this information concerns sensitive and limited officialuse only records that potentially pose a threat to institution security and inmate safety. 3. Defendants object to the disclosure of sensitive information identified in

paragraph 2 above, unless the disclosure of this information is authorized and governed pursuant to a Protective Order. This Protective Order would prohibit Plaintiff's counsel from showing, producing, or disseminating copies of any such records containing sensitive information to Plaintiff. However, this Protective Order is narrowly tailored such that it would not prohibit Plaintiff's counsel from discussing the sensitive information contained in those records with Plaintiff. WHEREFORE, the parties respectfully request that the Court sign and enter the Protective Order submitted with this Motion. Respectfully submitted this 25th day of July, 2006.

WILLIAM J. LEONE United States Attorney s/ Carmen Reilly Carmen Reilly Montgomery, Little 5445 DTC Parkway, #800 Englewood, CO 80111-3053 Telephone: (303) 779-2719 Email: [email protected] Attorney for Plaintiff s/ Amanda Rocque Amanda Rocque Assistant United States Attorney 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0109 Email: [email protected] Attorneys for Defendant

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Case 1:03-cv-01959-MSK-PAC

Document 227

Filed 07/25/2006

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CERTIFICATE OF MAILING I hereby certify that on this 25th day of July, 2006, I electronically filed the foregoing STIPULATED MOTION FOR ENTRY OF PROTECTIVE ORDER with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following email addresses: Carmen Nicole Reilly [email protected] [email protected] John Robert Riley [email protected] I hereby certify that on this 25th day of July, 2006, I served the foregoing STIPULATED MOTION FOR ENTRY OF PROTECTIVE ORDER on the following nonCM/ECF participants via electronic mail: Christopher Synsvoll, Esq. [email protected]

s/ Amanda Rocque Amanda Rocque Assistant United States Attorney 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0109 Facsimile: (303) 454-0404 Email: [email protected]

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