HomeMy WebLinkAbout2017CV493 - Howard V. City Of Fort Collins, Et Al - 018 - Stipulated Motion For Protective Order1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:17-cv-00493-RPM
EUGENE HOWARD,
Plaintiff,
v.
CITY OF FORT COLLINS, and
KATHLEEN WALKER,
Defendants.
STIPULATED MOTION FOR PROTECTIVE ORDER
Pursuant to Fed. R. Civ. P. 26(c) and 29, Plaintiff Eugene Howard and Defendants the City
of Fort Collins and Kathleen Walker through their respective undersigned counsel, having
previously conferred, jointly request this Court to enter a Stipulated Protective Order between
Plaintiff and Defendants concerning the discovery and/or dissemination of certain confidential
information in this case or information that will improperly annoy, embarrass, or oppress any party,
witness, or person providing discovery in this case in the form simultaneously tendered to the
Court with this Motion. As grounds for this Motion, Plaintiff and Defendants state:
1. Discoverable information in this case includes certain confidential information and
information that may improperly annoy, embarrass, or oppress a party, witness, or person
providing discovery in this case. Release of this information, including documents, in discovery
without a protective order to limit its use, to continue its confidential status, and to prevent any
Case 1:17-cv-00493-RPM Document 18 Filed 09/21/17 USDC Colorado Page 1 of 3
2
improper annoyance, embarrassment, or oppression to any party, witness, or person providing
discovery in this case will be injurious to the interests of the parties.
2. It is Plaintiff and Defendants’ desire and objective to facilitate the smooth and
timely production of discoverable information in this case. However, for the reasons described
above, the production and subsequent use of some of that information needs to be subject to certain
controls and restrictions.
3. Plaintiff and Defendants and their respective counsel have agreed to certain
procedures and restrictions which they consider mutually acceptable for the purpose of resolving
the above-described concerns. Those procedures and restrictions are recited in the Proposed
Stipulated Protective Order which is being tendered to the Court with this Motion.
WHEREFORE, Plaintiff Eugene Howard and Defendants the City of Fort Collins and
Kathleen Walker jointly request the Court to enter the Stipulated Protective Order which is being
tendered with this Motion.
Dated this 21ST day of September 2017.
Respectfully submitted,
S/ Mark S. Bove
________________________
Mark S. Bove
730 17th Street, Suite 635
Denver, CO 80202
T: 303-393-6666
Email: msbove@aol.com
ATTORNEY FOR PLAINTIFF
Respectfully submitted,
S/ Katherine M.L. Pratt
___________________________
Cathy Havener Greer
Katherine M.L. Pratt
Wells, Anderson & Race, LLC
1700 Broadway, Suite 1020
Denver, CO 80290
Telephone: (303) 830-1212
E-mail:cgreer@warllc.com
Email: kpratt@warllc.com
ATTORNEYS FOR DEFENDANTS
Case 1:17-cv-00493-RPM Document 18 Filed 09/21/17 USDC Colorado Page 2 of 3
3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on September 21, 2017, a true and correct copy of the above
and foregoing STIPULATED MOTION FOR PROTECTIVE ORDER was electronically filed
with the Clerk of Court using the CM/ECF system, which will send notification of such filing to
the following email address:
Mark S. Bove
730 17th Street, Suite 635
Denver, CO 80202
T: 303-393-6666
Email: msbove@aol.com
S/ Barbara McCall
Barbara McCall
Email: bmccall@warllc.com
Case 1:17-cv-00493-RPM Document 18 Filed 09/21/17 USDC Colorado Page 3 of 3