Free Motion for Protective Order - District Court of Colorado - Colorado

Case 1:04-cv-00865-REB-CBS

Document 113-4

Filed 09/01/2005

Page 1 of 3

EXHIBIT B

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 04-cv- 0865- REB- CBS
ESTATE OF APRil

Hill, SCOTT Hill , personal representative;

SCOTT Hill, as Conservator of the Estate of Katelyn Hill; and

SCOTT Hill , individually,
Plaintiffs,

vs.
AllSTATE INSURANCE COMPANY; MERASTAR INSURANCE COMPANY; AND PRUDENTIAL INSURANCE COMPANY OF AMERICA

Defendants.

AFFIDAVIT

STATE OF COLORADO
) ss.

COUNTY OF
, being first duly sworn, depose and
state as follows:

During the course of this civil action , I received Confidential Information

as that term is defined in the Stipulated Protective Order entered by the Court dated
, 2005, from

I certify that I have either returned all Confidential Information produced by

to that party s counsel of record in this action , or destroyed all

Case 1:04-cv-00865-REB-CBS

Document 113-4

Filed 09/01/2005

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Confidential Information that was produced by that party and is in my possession

custody, or control. The return or destruction of such Confidential

Information includes

but is not limited to , any copies; extracts; summaries that have been prepared by me,

counsel representing me or my employer in this litigation , and/or experts or other

individuals acting on my or my employer s behalf; copies maintained on electronic
storage devices , including but not limited to , computer databases, hard drives, and

floppy diskettes; and the portions of all transcripts of depositions and testimony that
contain or reference Confidential Information.

Except in accordance with the above-referenced Stipulated Protective

Order , I have not either personally or through any representatives or entities retained or
maintained any other party s
Confidential Information ,

including but not limited to , any

copies; extracts; summaries that have been prepared by me, counsel representing me

or my employer in this litigation, and/or experts or other individuals acting on my or my

employer s behalf; copies maintained on electronic storage devices, including but not
limited to, computer databases, hard drives, and floppy diskettes; and the portions of all

transcripts of depositions and testimony that contain or reference Confidential

Information.

Case 1:04-cv-00865-REB-CBS

Document 113-4

Filed 09/01/2005

Page 3 of 3

I have sent the original of this affidavit , via facsimile and U. S.

mail ,

to each

Party that has produced Confidential Information to me during the pendency of this

action , within thirty (30) business days of the final resolution of this lawsuit.

The foregoing Affidavit was acknowledged , subscribed , and sworn to before me

this

day of

200

(SEAL)

Notary Public
My Commission Expires:

395161v3