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Gross-Rubio v. Metropolitan Life Insurance Co.

United States District Court, D. Nevada

March 31, 2017

GINA GROSS-RUBIO, an individual, Plaintiff,
v.
METROPOLITAN LIFE INSURANCE COMPANY, a New York Corporation; DOES I through X, Inclusive; and ROE CORPORATIONS XI through XX, Inclusive, Defendants. METROPOLITAN LIFE INSURANCE COMPANY, a New York Corporation, Counterclaimant,
v.
GINA GROSS-RUBIO, an individual, Counterdefendant.

          KRISTINA N. HOLMSTROM Nevada Bar No. 10086 LEWIS ROCA ROTHGERBER CHRISTIE LLP Attorneys for Defendant Metropolitan Life Insurance Company

          PROTECTIVE ORDER REGARDING CONFIDENTIAL MATERIAL

          RICHARD F. BOULWARE, II United States District Judge

         Pursuant to the Minutes from the September 29, 2016 proceedings (Doc. 68), Defendant METROPOLITAN LIFE INSURANCE COMPANY (“MetLife”) submits the proposed Protective Order:

         1.

         This Order shall apply to the production by MetLife of any claim guidelines (“the guidelines”), and to any information or testimony pertaining to the guidelines, during this litigation.

         2.

         No document or information provided under Paragraph 1 may be disclosed to any person, except for the following:

         (a) Counsel of record; (b) the parties; (c) employees of the parties; (d) persons assisting counsel of record, including office staff of counsel, and other individuals retained by the parties and/or counsel for the parties to whom it is necessary that the material be disclosed for purposes of this litigation, and who agree to comply with this Order; and (e) any deponent whose testimony relates to the content of the guidelines, provided that the deponent agrees to comply with this Order.

         3.

         All such documents and information MetLife produces pursuant to paragraph 1 shall be deemed “Confidential” and used only in the course of this action, including for use as evidence in any trial herein, if admissible, and shall not be used or provided for use in any other litigation or proceedings, and specifically shall not be disclosed to other parties in other litigation against MetLife, and shall not be disclosed to anyone at any time other than as specifically provided herein.

         4.

         The documents and information MetLife produces to Plaintiff and/or counsel for Plaintiff pursuant to paragraph 1 shall not be published orally, electronically, by copy, or by any other means to any person other than persons enumerated in paragraph 2 of this Order.

         5.

         Upon conclusion of this action, Plaintiff and/or counsel for Plaintiff shall return to MetLife the original and all copies made of such documents described in paragraph 1 within 30 ...


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