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Leany v. Zurich American Insurance Co.

United States District Court, D. Nevada

April 4, 2017

TODD L. LEANY, Plaintiff,
v.
ZURICH AMERICAN INSURANCE COMPANY, a New York corporation, Defendant. ZURICH AMERICAN INSURANCE COMPANY, Counterclaimant,
v.
TODD L. LEANY, CounterDefendant.

          Abran E. Vigil, Maria A. Gall, Joseph P. Sakai, Ballard Spahr LLP Attorneys for Defendant and Counter-Claimant Zurich American Insurance Company

          BALLARD SPAHR LLP, Joseph P. Sakai Abran E. Vigil, Maria A. Gall, Joseph P. Sakai Attorneys for Defendant/Counterclaimant Zurich American Insurance Company

          ALBRIGHT, STODDARD, WARNICK & ALBRIGHT, William H. Stoddard, Jr. D. Chris Albright, Esq., William H. Stoddard, Jr., Esq. South Rancho Drive, Attorneys for Plaintiff/Counter- Defendant Todd L. Leany

          STIPULATED PROTECTIVE ORDER

         The parties to this action, by their respective counsel, having agreed to the following, and for good cause shown, IT IS HEREBY ORDERED as follows:

         1. PURPOSE AND LIMITATIONS.

         Disclosure and discovery activity in this action may involve production of confidential, proprietary, or private information for which special protection from public disclosure may be warranted. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under law to treatment as confidential.

         2. SCOPE.

         All documents produced in the course of discovery, all responses to discovery requests, and all deposition testimony and exhibits and any other materials which may be subject to discovery, including subpoenaed documents (hereinafter collectively “documents”), shall be subject to this stipulated protective order concerning confidential information as set forth below. Any party, or any third party who produces documents in this litigation, may designate documents as CONFIDENTIAL but only after review of the documents by an attorney who has, in good faith, determined that the documents contain “Confidential Information, ” as defined below, and pursuant to the procedure set forth below.

         3. CONFIDENTIAL INFORMATION.

         “Confidential Information” shall mean any information, testimony, document, or thing that contains confidential or proprietary information, such as trade secret, financial information, or commercial information concerning a business's customers, vendors, personnel and operations. Nothing in this paragraph shall be construed as an exclusion of any other material from the definition of “Confidential Information.”

         Confidential Information does not include information that: (a) is in the public domain at the time of disclosure; (b) becomes part of the public domain through no fault of the Receiving Party; (c) the Receiving Party can show was in its rightful and lawful possession at the time of disclosure; or (d) the Receiving Party lawfully receives from a Non-Party later without restriction as to disclosure.

         4. OTHER DEFINITIONS.

         Party: any party to this action and attorney(s) of record for a Party in this action, including their associates, paralegals, and support/clerical staff.

         Non-Party: any individual, corporation, association, or natural person or entity other than a Party.

         Protected Material: any disclosure or discovery material that is designated by a Party or Non-Party as “CONFIDENTIAL, ” unless the Receiving Party challenges the confidentiality designation and (a) the Court decides such material is not entitled to protection as confidential; (b) the Designating Party fails to apply to the Court for an order designating the material confidential within the time period specified in Section 9 below; or (c) the Designating Party withdraws its confidentiality designation in writing.

         Producing Party: a Party or Non-Party that produces disclosures or discovery material in this action.

         Receiving Party: a Party that receives disclosures or discovery material from a Producing Party.

         Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as Protected Material. The Party or Non-Party designating information or items as Protected Material bears the burden of establishing good cause for the confidentiality of all such items.

         Challenging Party: a party that elects to initiate a challenge to a Designating Party's confidentiality designation.

         Arbitration: the arbitration between Zurich American Insurance Company, as claimant, and Century Steel, Inc., as respondent, currently pending before the American Arbitration Association as Case No. 01-16-0003-1446.

         Arbitrators: the arbitrators appointed to the Arbitration, Richard J. Collier, Esq., Thomas G. Ryan, Esq., and William C. Turner, Esq., and any further arbitrator that may be appointed in the Arbitration.

         5. FORM AND ...


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