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.

Medchoice Risk Retention Group, Inc. v. Rand

United States District Court, D. Nevada

November 30, 2017

MEDCHOICE RISK RETENTION GROUP, INC. Plaintiff,
v.
ROBERT G. RAND. M.D.. and RAND FAMILY CARE LLC Defendant.

          COZEN O'CONNOR Shauna Martin Ehlert Michael W. Melendez Attorneys for Plaintiff.

          PERRY & WESTBROOK Victor Alan Perry Attorney for Defendants.

          STIPULATED MOTION FOR PROTECTIVE ORDER

         Pursuant to Federal Rule of Civil Procedure 26, Plaintiff MedChoice Risk Retention Group, Inc. ("MedChoice"'), and Defendants Robert G. Rand, M.D. and Rand Family Care LLC (collectively "Rand") (collectively, MedChoice and Rand are referred to herein as the "Parties"; individually each may be referred to as a "Parly") deem it appropriate to limit the disclosure of certain confidential information, as set forth below, and MedChoice and Rand, by counsel, have stipulated and agreed to give effect to the stipulations set forth below.

         IT IS HEREBY ORDERED THAT:

         1. Purposes and Limitations. Disclosure and discovery activity in this Action is likely to involve production of confidential, proprietary, or private information for which special protection is warranted from:

         (a) public disclosure;

         (b) disclosure to the "Underlying Plaintiffs" (and their counsel) in the "Underlying Actions:"

Cyndi Papez Yenick v. Robert Rand, M.D., et al., Washoe County District Court Case No. CV-16-01004 (the "Yenick Lawsuit"); and/or
Eric Zuhlke v. Robert Rand. M.D., et al., Washoe County District Court Case No. CV16-01641 (the "Zuhlke Lawsuit") and/or
Don Robertson, II, v. Robert Rand. M.D.; Rand Family Care, Washoe County District Court, Case No. CV 17-0099 (the "Fribourg Lawsuit")

         (collectively, the Yenick Lawsuit, the Zuhlke Lawsuit, and the Fribourg Lawsuit are referred to herein as the "Underlying Actions"; each of the Plaintiffs in the Underlying Actions may be referred to as "Underlying Plaintiffs"); and

         (c) use for any purpose other than this litigation.

         The Parties therefore stipulate to and request entry of this Protective Order (the "Order") by the Court. 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 the applicable legal principles to treatment as confidential. The Parties further acknowledge that this Order does not allow any Party to file anything under seal. The applicable rules, including Federal Rule of Civil Procedure 5.2 and LR 1A 10-5 set forth the procedures that must be followed and reflect the standards and procedures that will be applied when a Party seeks leave to file material under seal.

         2. Discovery Material. Documents, discovery responses, including interrogatory responses, responses to requests for admission, etc., deposition testimony, photographs, videotapes, data and other materials, or portions thereof, produced in discovery in this Action by any of the Parties (the "Producing Party") may be designated as "Confidential" if the Producing Party reasonably and in good faith believes they contain confidential commercial, personal, financial, or proprietary information, medical records, or other confidential information not already part of the public domain, including all ...


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.