IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO 

Civil Action No. 11-cv-02408-CMA-KMT 

SENAD GLUHIC, 

 Plaintiff, 

vs. 

SAFEWAY INC., 

 Defendant. 

STIPULATED PROTECTIVE ORDER 

Plaintiff Senad Gluhic, by and through his counsel, Chan Law Firm, and Defendant 

Safeway, Inc., by and through its counsel, Holland & Hart LLP, hereby stipulate and agree as 

follows, and the Court, having been fully advised, hereby ORDERS as follows: 

1. All production and disclosure of “Confidential Information” as defined in 

paragraph 2 below shall be governed by this Order. 

2. “Confidential Information” as used herein includes, but is not limited to, 

documents, materials, and information (in electronic, hard copy, or any other form or media), 

including without limitation, documents produced, answers to interrogatories, responses to 

requests for admission, deposition testimony, and other information disclosed pursuant to 

discovery in this case and designated as “Confidential” pursuant to the terms of this Protective 

Order. In general, Confidential Information includes and may be claimed with respect to: 

a. Information concerning present or former employees of Defendant, such 

as pay, benefits, hours worked, pay rates, personnel files, and other personal information; 

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b. Confidential and proprietary business information regarding Defendant 

and its operations, contracts, customers, processes, and equipment; and 

c. Any other information reasonably deemed to be of a confidential or 

proprietary nature by the designating party. 

The parties shall endeavor to limit the designation of information as Confidential Information to 

the information that genuinely warrants the protection provided by the terms of this Order. 

3. Documents may be designated as Confidential by placing or affixing on them (in 

a manner that will not interfere with their legibility) the following or other appropriate notice: 

“CONFIDENTIAL.” In lieu of marking the original documents, a party may mark the copies 

that are produced or exchanged. 

4. Confidential documents, materials, and/or information shall be used solely for the 

purpose of prosecution or defense of this action, and such documents may only be used, 

consistent with the terms of this Order, in pretrial discovery, the trial or preparation for trial, or 

any appeal of this action; provided, however, any party may use its own Confidential 

Information for any purpose whatsoever. The use of Confidential Information at the trial or in 

pretrial discovery or other proceedings shall not be deemed a waiver of the protections of this 

Order. 

5. Documents labeled “Confidential” shall not, without the consent of the party 

producing it or further Order of the Court, be disclosed except that such information may be 

disclosed to: 

a. Attorneys for each party actively engaged in this litigation; including, but 

not limited to, attorneys from Holland & Hart LLP and Chan Law Firm; 

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b. Persons regularly employed or associated with the attorneys and actively 

engaged in this litigation; 

c. Plaintiff, provided, however, that Plaintiff may only review such material, 

or a copy of such material, at the office of her counsel; 

d. Current directors, officers, and employees of Defendant who need to 

review such documents to assist in the litigation of this matter; 

e. Expert witnesses and consultants retained in connection with this 

proceeding, to the extent such disclosure is necessary for preparation, trial or other 

proceedings in this case; 

f. The Court, jurors, and court staff involved in this case; 

g. Stenographic reporters who are engaged in proceedings necessarily 

incident to the conduct of this action; 

h. Deponents, witnesses, or potential witnesses who are reasonably expected 

to testify at deposition or trial; 

i. Other persons by written agreement of the parties; and 

j. Outside vendors who perform indexing, photocopying, or similar clerical 

functions for the parties’ attorneys. 

6. Any party objecting to the designation of any information as Confidential shall 

clearly state the basis for the objection in a written notice to counsel for the party making the 

designation. The written notice shall identify the information to which the objection is made. If 

the parties are unable to resolve the objection within fourteen (14) days after the time the notice 

is received, the party objecting to the confidential designation shall within twenty-one (21) days 

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of the aforementioned notice file an appropriate motion with the Court requesting resolution of 

the matter, otherwise any objection is waived. Until an objection to the designation of 

information has been resolved by agreement of counsel or by order of the Court, the information 

shall be deemed to be properly designated and subject to the terms of this Order. The party 

making the designation in question shall bear the burden of justifying that designation in any 

dispute before the Court requesting modification or striking of the designation. 

7. This Order shall continue to be binding throughout and after the conclusion of the 

hearing, including any appeal thereof. Upon conclusion of this case, upon written request, any 

and all copies of the opposing party’s Confidential documents shall be returned to opposing 

counsel or destroyed by counsel, who shall so certify to opposing counsel. Notwithstanding the 

foregoing, all briefs, pleadings, or other filings with the Court, or attorney work product which 

incorporates or discloses material covered by this Order may remain in the possession of 

counsel, and need not be destroyed, but shall remain subject to this Order. 

8. The terms of this Order may be modified by further order of the Court upon good 

cause shown. 

DONE AND ORDERED this 10th day of July, 2012. 

BY THE COURT: 

 

Kathleen M. Tafoya 

United States Magistrate Judge 

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STIPULATED TO AND APPROVED AS TO FORM: 

5663607_1.DOCX 

s/Catherine A. Chan 

Catherine A. Chan 

Chan Law Firm 

1900 Grant Street, Suite 750 

Denver, CO 80203 

(303) 586-5555 

E-mail: cchan@chanimmigration.com 

ATTORNEY FOR PLAINTIFF 

s/Gregory A. Eurich 

Gregory A. Eurich, Esq. 

Joseph Neguse, Esq. 

HOLLAND & HART LLP

555 Seventeenth Street, Suite 3200 

Denver, CO 80202 

Telephone: (303) 295-8166 

(303) 295-8443 

Fax: (303) 975-5464 

(720) 545-2089 

E-mail: geurich@hollandhart.com 

jneguse@hollandhart.com 

ATTORNEYS FOR DEFENDANT

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