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Rohde v. Progressive Direct Insurance Company

United States District Court, D. Nevada

August 30, 2017

RANDY ROHDE, Plaintiff,
v.
PROGRESSIVE DIRECT INSURANCE COMPANY; DOES I through X, inclusive, ROE CORPORATIONS I through X, inclusive, Defendants.

          RYAN L. DENNETT, ESQ., MATTHEW J. WAGNER, ESQ. DENNETT WINSPEAR, LLP Attorneys for Progressive Direct Insurance Company

          JULIE A.MERSCH, ESQ. LAW OFFICES OF JULIE A. MERSCH Attorneys for Plaintiff, RANDY ROHDE

          STIPULATION AND ORDER REGARDING CONFIDENTIALITY AGREEMENT

         PLAINTIFF, RANDY ROHDE, by and through his counsel of record, Julie A. Mersch, Esq., of the LAW OFFICE OF JULIE A MERSCH; and DEFENDANT, PROGRESSIVE DIRECT INSURANCE COMPANY (hereinafter "PROGRESSIVE INSURANCE"), by and through its counsel of record, Ryan L. Dennett, Esq. of the law firm of DENNETT WINSPEAR, LLP, hereby enter into the following STIPULATION AND ORDER REGARDING CONFIDENTIALITY AGREEMENT:

WHEREAS PLAINTIFF has filed the above-identified suit against DEFENDANT, PROGRESSIVE INSURANCE;
WHEREAS PROGRESSIVE INSURANCE was served with Plaintiff's request for production of documents at the LR-26 Meet and Confer Meeting and anticipates that PROGRESSIVE INSURANCE may be served with additional requests for documents in connection with the instant suit;
WHEREAS PROGRESSIVE INSURANCE has asserted a privilege and will continue to assert a privilege, that the materials to be disclosed and sought by PLAINTIFF are of a confidential or proprietary nature and constitute a trade secret under applicable law, and will assert such a privilege from disclosure of documents and discovery as to any current and future requests for production of documents;
WHEREAS PLAINTIFF and DEFENDANT PROGRESSIVE INSURANCE desire to expedite and facilitate the discovery process in this litigation while protecting the business interests of PROGRESSIVE INSURANCE to its trade secrets; and
WHEREAS PLAINTIFF and DEFENDANT PROGRESSIVE INSURANCE agree that the easiest and most economical way to accomplish this goal is through the execution of this STIPULATION AND ORDER REGARDING CONFIDENTIALITY AGREEMENT.

         IT IS THEREFORE AGREED as follows:

         1. Documents that will be produced by PROGRESSIVE INSURANCE and designated as “Confidential” as provided pursuant to this STIPULATION AND ORDER REGARDING CONFIDENTIALITY AGREEMENT are claimed by PROGRESSIVE INSURANCE to be of a confidential or proprietary nature by PROGRESSIVE INSURANCE at or about the time of the incident or transactions at issue in this litigation or at some time later. The purpose of this STIPULATION AND ORDER REGARDING CONFIDENTIALITY AGREEMENT is to protect the confidentiality of these documents.

         2. Documents and information produced in this case by PROGRESSIVE INSURANCE shall be protected from inappropriate disclosure in accordance with the following terms and conditions:

a. PROGRESSIVE INSURANCE may, in good faith, designate documents or discovery information “confidential” including, but not limited to:
i. All documents and/or information that Defendant believes to constitute or disclose trade secrets or other confidential research, development, testing, or commercial information or other information that it is entitled to keep in confidence;
ii. Business marketing, testing, training materials, research or strategic plans relating to any materials, products, ...

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