Cox v. Wilson
Filing
29
STIPULATED PROTECTIVE ORDER by Magistrate Judge Nina Y. Wang on 7/9/15. (bsimm, )
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
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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
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