Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Allstate Insurance Co. v. Nassiri

United States District Court, D. Nevada

May 3, 2017

ALLSTATE INSURANCE COMPANY, et al., Plaintiffs,
v.
OBTEEN N. NASSIRI, D.C., et al., Defendants.

          FRIZELL LAW FIRM, PLLC R. DUANE FRIZELL, ESQ. Nevada Bar No. 9807 Attorney for Medical-Training Defendants.

          HUTCHISON & STEFFAN, LLC TODD L. MOODY, ESQ. Nevada Bar No. 5430 RICHARD L. WADE, ESQ. Nevada Bar No. 11879 Attorneys for Nassiri Defendants.

          GERRARD COX LARSEN DOUGLAS D. GERRARD, ESQ. Nevada Bar No. 4613 JOHN M. LANGEVELD ESQ. Nevada Bar No. 11628 Attorneys for Andersen Defendants.

          MCCORMICK, BARSTOW, SHEPPPARD, WAYTE & CARRUTH LLP JARED P. GREEN, ESQ. Nevada Bar No. 10059 DYLAN P. TODD, ESQ. Nevada Bar No. 10456 Attorneys for Plaintiffs.

          STIPULATION AND PROTECTIVE ORDER

         Plaintiffs ALLSTATE INSURANCE COMPANY, ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY, and ALLSTATE INDEMNITY COMPANY (collectively, “Plaintiffs”); Defendants OBTEEN NASSIRI, JENNIFER NASSIRI, HARLEY TRUCK, LLC, and DAA TRUST (collectively, “Nassiri Defendants”); and Defendants JIM ANDERSEN, CHRISTYN ANDERSEN, ANDERSON FAMILY TRUST, 181 RUSTY PLANK, LLC, and ADROON, LLC (collectively, “Andersen Defendants”); and Defendants FAA FOI TUITAMA, ADVANCED MED LLC, and GREEN TREE SERVICES LLC (collectively, “Medical-Training Defendants”) hereby tender to the Court this Stipulation and Protective Order. In this connection, these Plaintiff and these Defendants (each a “Party” and collectively the “Parties”) hereby stipulate and agree as follows:

         1. Purpose.

         The contents of private financial, proprietary, and/or related information pertaining to the parties are deserving of protection under FRCP 26(c). This protective order is intended to govern the use and dissemination of this Covered Information, which may contain or be referenced in all documents and discovery material produced by the parties, whether informally or formally, in response to interrogatories, requests for admissions, or requests for production, or obtained by or submitted to the parties, the Court, or both through affidavit, record or other testimony, deposition, or otherwise.

         2. Designation of “Confidential Information”.

         The designation “Confidential Information” shall include any and all information relating to the parties' financial, proprietary, and/or related information. When documents are produced in discovery and/or pursuant to FRCP 26(a), they may be designated as confidential by Bates Number. In addition, all confidential documents shall be marked “CONFIDENTIAL” in a conspicuous place on the face of each page of the document.

         3. Designation of “Attorney's Eyes Only”.

         The designation “Attorney's Eyes Only” shall be limited to information that the disclosing party reasonably believes contains a trade secret, is of a highly sensitive commercial nature, or should otherwise be subject to “Attorney's Eyes Only” treatment. Examples of such information include, but are not limited to, documents reflecting, containing, or derived from Confidential Information regarding current pricing, production, cost, marketing, strategic planning, or customers. Pricing and marketing information concerning past business dealings between the parties, and other information which is known to the parties independent of this litigation shall be subject to the “Confidential Information” designation only; however, such information concerning third parties may be designated “Attorneys' Eyes Only.” When documents are produced in discovery and/or pursuant to FRCP 26(a), they may be designated as being for attorney's eyes only by Bates Number. In addition, all such documents shall be marked “ATTORNEY'S EYES ONLY” in a conspicuous place on the face of each page of the document.

         4. “Covered Information” Defined.

         As used herein, the term “Covered Information” refers to and includes information and documents designated as “Confidential Information, ” “Attorney's Eyes Only, ” or both.

         5. Qualified Persons to Review Confidential Information.

         Confidential Information produced pursuant to this Order may be disclosed or made available only to the persons set forth below:

(a) The parties (if not natural persons, then the employees, principals or agents of the parties who are actively involved in assisting with the prosecution or defense of this action);
(b) In-house counsel for the parties who are actively involved in the prosecution or defense of this action;
(c) Outside counsel for the parties;
(d) Consulting or testifying experts retained by counsel in this litigation;
(e) The Court;
(f) Court reporters (including audio and ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.