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Grogan v. State Farm Mutual Automobile Insurance Co.

United States District Court, D. Nevada

July 9, 2018

PAMELA GROGAN, individually Plaintiff,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, an entity licensed to do business in Nevada; DOES I through X; and ROE CORPORATIONS, XI through XX, inclusive Defendant

          RANALLI ZANIEL FOWLER & MORAN, LLC GEORGE M. RANALLI, ESQ. Nevada Bar No. 5748 BENJAMIN J. CARMAN, ESQ. Nevada Bar No. 12565 Attorneys for Defendant

          HENNESS & HAIGHT MARK G. HENNESS, ESQ. Nevada Bar No. 5842 JACOB S. SMITH, ESQ. Nevada Bar No. 10231 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 ("Protected Documents"); and

         WHEREAS Plaintiff to this action PAMELA GROGAN (“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. Defendant shall stamp any documents to be produced subject to this protective order with a notation on each page stating the following:

PROTECTED DOCUMENT
State Farm adv. Grogan, United States District Court, District of Nevada No. 2:17-cv-01044-APG-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 direct supervision of the counsel of record;
(c) The parties' experts, consultants, agents, employees, officers, directors, and investigators who are or will be consulted or retained to assist the parties in their preparation for and conduct of ...

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