Williamson v. G4S Secure Solutions, Inc. (USA)

Filing 31

STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION signed by Magistrate Judge Craig B. Shaffer on 12/17/12. (cbssec)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No.: 11-cv-03402-PAB-CBS
JAMES WILLIAMSON,
Plaintiff,
v.
G4S SECURE SOLUTIONS (USA), INC.,
G4S SECURE SOLUTIONS INTERNATIONAL, INC., and,
G4S SECURE SOLUTIONS, DENVER,
Defendants.

STIPULATED PROTECTIVE ORDER
CONCERNING CONFIDENTIAL INFORMATION

The parties, by and through their respective counsel, stipulate to the entry of this
Protective Order Concerning Confidential Information, as follows:
1.

This protective order applies to all documents, materials, information, and

deposition testimony marked “CONFIDENTIAL” by a party that a party provides or discloses to
an opposing party during this litigation.
2.

Fed.R.Civ.P. 34 (a) (1) (A) provides the definition of “document” in this order. A

draft or non-identical copy is a separate document within the meaning of this term.
3.

"CONFIDENTIAL INFORMATION” means documents, materials, information,

and testimony a party provides or discloses during this litigation that is marked or designated
“CONFIDENTIAL” and is proprietary, confidential and not publicly available, or that implicates
a privilege or legitimate privacy interest.

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4.

Documents a party intends to mark “CONFIDENTIAL” must first be reviewed by

a lawyer for the party who will certify the “CONFIDENTIAL” designation is based on a good
faith belief the information in the documents is confidential or otherwise entitled to protection.
5.

CONFIDENTIAL INFORMATION must not be disclosed or used for any

purpose except the preparation and trial of this case.
6.

CONFIDENTIAL INFORMATION must not be disclosed without the consent of

the party producing it or further order of the court, except such information may be disclosed to:
(a) attorneys working on this case;
(b) persons regularly employed or associated with the attorneys working on the
case whose assistance is required by said attorneys to prepare for trial, at trial, or at other
proceedings in this case;
(c) the parties and designated representatives for the entity defendants;
(d) expert witnesses and consultants retained in connection with this case, 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 engaged in proceedings necessarily incident to the
conduct of this action;
(g) deponents, witnesses, or potential witnesses; and,
(h) other persons by written agreement of the parties.
7.

Documents are designated confidential by clearly and conspicuously placing or

affixing on them the word “CONFIDENTIAL,” or other appropriate notice, in a manner that will
not interfere with their legibility.

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8.

Whenever a deposition involves the disclosure of information a party regards as

confidential, such party shall designate the information CONFIDENTIAL on the record during
the deposition whenever possible, but a party may designate portions of depositions as
CONFIDENTIAL after transcription, provided written notice of the designation is promptly
given to all counsel of record within thirty (30) days after notice by the court reporter of the
completion of the transcript.
9.

A party may object to the designation of particular CONFIDENTIAL information

by giving written notice to the party designating the disputed information. The written notice
shall identify the information to which the objection is made. If the parties cannot resolve the
objection within ten business days 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 that the court determine whether the disputed information should be subject to the
terms of this protective order within 30 days of the aforementioned notice. If such a motion is
timely filed, the disputed information shall be treated as CONFIDENTIAL under the terms of
this protective order until the court rules on the motion. If the designating party fails to file such
a motion within the prescribed time, the disputed information shall lose its designation as
CONFIDENTIAL and shall not thereafter be treated as CONFIDENTIAL INFORMATION in
accordance with this protective order. In connection with a motion filed under this provision, the
party designating the information as CONFIDENTIAL shall bear the burden of establishing that
good cause exists for the disputed information to be treated as CONFIDENTIAL.
10.

As with all court filings, the parties shall comply with D.C.COLO.LCivR 7.2 as to

any request to restrict access based on this protective order.

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11.

This protective order may be modified by the court at any time for good cause

shown following notice to all parties and an opportunity for them to be heard.

DATED at Denver, Colorado, on December 17, 2012.
BY THE COURT:

s/Craig B. Shaffer
Craig B. Shaffer
United States Magistrate Judge

STIPULATED TO AND APPROVED AS TO FORM this 14th day of December, 2012.
s/ Eric V. Field
Eric V. Field
The Law Offices of Sandomire & Schwartz
281 South Pearl Street
Denver, CO 80209
[phone] - Telephone
[phone] - Fax
[e-mail]

s/ Peter F. Munger
Peter F. Munger
Ryan P. Lessmann
JACKSON LEWIS LLP
950 Seventeenth Street, Suite 2600
Denver, CO 80202
[phone] – Telephone
[phone] - Fax
[e-mail]
[e-mail]

ATTORNEYS FOR PLAINTIFF

ATTORNEYS FOR DEFENDANTS

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