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.

Chacon v. State Farm Automobile Insurance Co.

United States District Court, D. Nevada

July 5, 2017

GERARDO CHACON Plaintiff,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY; ROE INSURANCE COMPANY; DOES I through X, inclusive, and ROE CORPORATIONS I through X, inclusive Defendant

          RANALLI ZANIEL FOWLER & MORAN, LLC GEORGE M. RANALLI, ESQ. BENJAMIN J. CARMAN, ESQ. Attorneys for Defendant.

          G. DALLAS HORTON & ASSOCIATES DAVID L. THOMAS, ESQ. Attorney for Plaintiff.

          STIPULATION AND ORDER FOR PROTECTIVE ORDER

         WHEREAS Defendant, STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, (“Defendant”) has in its possession or under its control certain documents, testimony, or information that may contain or comprise attorney-client documents, work product documents, trade secrets documents, and personal information and financial documents which are considered confidential, sensitive and/or proprietary by Defendant (hereinafter the "Protected Documents"); and

         WHEREAS Plaintiff to this action GERARDO CHACON (“Plaintiff”) without conceding privacy, the confidentiality, sensitivity or proprietary nature of such documents, wishes to have access to the Protected Documents for purposes of prosecuting this lawsuit;

         WHEREAS Defendant contends that it could suffer irreparable harm if the Protected Documents or their contents were subjected to unauthorized disclosure; and, WHEREAS Plaintiff contends that Defendant might be required to also provide copies of such Protected documents to the other parties in this case not identified above;

         NOW, THEREFORE, the parties hereto hereby stipulate as follows:

         1. Any documents to be produced subject to this protective order shall, prior to being produced by Defendant, be stamped with a notation on each page thereof stating the following:

         PROTECTED DOCUMENT

State Farm adv. Chacon, United States District Court, District of Nevada Case No. 2:16-cv-00965-RFB-VCF.
This document is subject to a protective order. Unauthorized disclosure is prohibited.

         Failure to stamp any such document at the time of its production shall constitute a rebuttable presumption that such document is not subject to the terms and conditions of this protective order.

         2. Counsel for the parties receiving copies of Protected Documents stamped as provided in paragraph 1, above, shall treat such documents and their contents as confidential, to be used only for the purposes of this litigation. In particular, counsel shall not give, show or disclose the contents of any such document to any other person or entity except:

(a) The Court and its employees under seal;
(b) The parties' counsel of record, including partners and associate attorneys, and paralegal assistants, stenographic and clerical employees when working under the ...

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.