Cox v. Wilson

Filing 29

STIPULATED PROTECTIVE ORDER by Magistrate Judge Nina Y. Wang on 7/9/15. (bsimm, )

Download PDF
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 15-cv-00128-WJM-NYW CODY WILLIAM COX, Plaintiff, v. DON WILSON, in his individual capacity, Defendant. STIPULATED PROTECTIVE ORDER The parties, by their attorneys of record, stipulate and agree to the entry of the following protective order: 1. This protective order provides for the confidentiality of the remaining papers from Deputy Wilson’s Clear Creek County Sheriff’s Office personnel file that were not already provided to plaintiff’s counsel on April 29, 2015. Defendant will be producing these additional records in response to plaintiff’s request for production served under Fed. R. Civ. Proc. 34. 2. In order to identify records covered by this order, defense counsel will label or mark them as “Confidential” and “Subject to Protective Order.” 3. The records covered by this order and information contained in them shall be used only and solely in the above-captioned litigation, and for no other purpose. 4. Any testimony that plaintiff may desire concerning the records and information covered by this order shall be placed on a confidential record which shall be separated from the rest of the transcript and marked as confidential within the transcript and also on the exterior seal. 5. Plaintiff’s counsel may not share the confidential records or information contained in the confidential records with anyone outside of his firm unless: a. The purpose relates to the person’s service as a retained expert in this lawsuit; and b. The person first signs an acknowledgment of having read this order, agreeing to be bound, and submitting to the jurisdiction of the court for purposes of enforcement. 6. Plaintiff’s counsel shall retain all acknowledgments required above for two years after the litigation is concluded to be available for production to this court or any other court having proper jurisdiction. 7. If plaintiff desires to file any documents subject to this order with the Court, counsel shall follow the procedures set forth in D.C.Colo.L.CivR 7.2(c). 8. If confidential records are proposed to be used at trial, plaintiff’s counsel will notify defense counsel by 10 days before the deadline for the parties to submit a stipulated pretrial order. The attorneys will confer in an effort to reach agreement on the handling of such records at trial. If agreement is not reached, either party may seek a ruling from the court. 9. By no later than 10 days after the case concludes, whether by settlement or judgment, plaintiff’s counsel and any expert with whom plaintiff’s counsel has shared 2 records covered by this order shall destroy them and delete any copies they or staff members copied to or saved in any computers. DONE AND SIGNED this 9th day of July, 2015. BY THE COURT: s/ Nina Y. Wang United States Magistrate Judge Respectfully submitted, By: s/James F. Scherer James F. Scherer David B. Law MILLER & LAW, P.C. 1900 W. Littleton Blvd. Littleton, CO 80120 Telephone: (303) 722-6500 Fax: (303) 722.9270 E-mail: jfs@lpmlaw.com dbl@lpmlaw.com By: s/Leslie L. Schluter Leslie L. Schluter DAGNER | SCHLUTER | MITZNER | WERBER, LLC 5105 DTC Parkway, Suite 325 Greenwood Village, CO 80111 Telephone: (303) 221-4661 Fax: (303) 221-4594 E-mail: lschluter@lawincolorado.com ATTORNEYS FOR DEFENDANT ATTORNEYS FOR PLAINTIFF 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?