Free Protective Order - District Court of Arizona - Arizona

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6 UNITED STATES DISTRICT COURT
7 DISTRICT OF ARIZONA _
8 Matthew Shaffer, _ y
No. CIV-03-2344-PI-IX-FJl»I
9 ‘ Plaintiff, S7`! Pr/A-#7EB
_ PROTECTIVE ORDER
. 10 vs. _
11 State of Arizona Citizens Clean Election .
Commission; Colleen Connor and Chad Jacobs, - · _ _
12 husband and wife, and Jessica Funlchcuser and I
Lindy Eunkhouser, husband and wife; John n
13 Does LX; Jane Does I-X, _ . ‘
‘ 14 Defendants. .
15 It being represented to the Court that defendants State of Arizona Citizens Clean A
l6 _ Election Commission, Colleen Connor and Chad Jacobsphave requested documents and
17 infomation from plaintiff Matthew Shaffer, which involve plaintiffs federal and state tax
lg returns, including all pertinent forms and schedules, for the tax years 2002 through the date `
. lg of the trial of this case, including plaintiff s personal returns and returns for any business in
20 which he has any financial interest; and
21 E ‘ A it
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1 lt being represented to the Court that plaintiff is willing t0 provide, subject to _
2 appropriate objections, these documents for inspection review only under a protective
3 order upon the hereinafter stated terms and conditions; and Z°?-/ 2##`¤?.! Zz »/»}»é_
4 lt being r esented th the Court that all of the parties are in agreement as the Y
5 terms of the said protective order; therefore, I _ I
A6 It is hereby ORDERED that:· i
7 1. .Plaintiff will disclose documents that it designates "Confidential" to the
8 defendants to this suit and their attorneys, only pursuant to this Order and under the
i 9 conditions that follow. _ I ‘
10 2. Any and all of the aforesaid rnaterials disclosed by plaintiff and the contents
. 11 thereof shall be maintained in conndence by counsel for defendants. These Confidential
12 rnaterials shall not be photocopied or reproduced-by any means without the prior consent j I
13 of counsel for plaintiff or until further Order of this Court. _ I
14 2 3. Any all-of the Confidential materials and information contained therein I
. 15 disclosed by plaintiff and the contents thereof shall be used only in connection with the I
16 above—captioned matter and shall not be copied, used or disclosed for any other purpose
17 whatsoever. n
1 18 I 4. No person who examines any document produced pursuant to this Order
19 shall disseminate orally, in writing, electronically, or by any other means, the doc-urnents `
2O or the information contained therein, to any person not also specifically authorized to
_ 21 examine documents under the terms of this Order. _ _,
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1 5. Counsel for plaintiff and counsel for defendants to this litigation may permit
. 2 an expert- or experts hired by plaintiff or defendants in this litigation to review the
3 documents subject to this Protective Order, but counsel for plaintiff and counsel for -
4 defendants must first obtain from these experts a written statement connnning the experts
i 5 agreement to comply with every element of this Protective Order. These experts shall
6 agree that the documents and the contents thereof shall not be disclosed to any other
I 7 person or entity, and said documents shall not be photocopied or reproduced by any means.
3 I 6. Notwithstanding the foregoing provisions, this Order shall be without
9 prejudice to the right of any party to challenge the propriety of discovery on any grounds
10 net lirnited to, relevance, privilege and materi ality.
11 7. Notvvithstandingithe foregoing provisions, this Order shall not restrict in any J i
12 manner the right of any party to offer or use as evidence at the trial of this action any of the
13 documents subject to this Protective Order, and nothing contained herein shall be ·
14 construed as a waiver of any objection which might be raised as to theiadmissibility of any I
15 evidentiary material. _ I I i . I i
ld IDONE IN COURT £_?pday of July.
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19 ed - ‘· tes District Court Judge · I
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