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Employers Mutual Casualty Company v. Zurich American Insurance Company

United States District Court, D. Nevada

July 12, 2018

EMPLOYERS MUTUAL CASUALTY COMPANY, Plaintiff,
v.
ZURICH AMERICAN INSURANCE COMPANY; CATLIN SPECIALTY INSURANCE COMPANY; GREENWICH INSURANCE COMPANY, XL INSURANCE AMERICA, INC. and DOES 1 through 250, inclusive, Defendants.

          Laleaque Grad, Esq. THE GRAD LAW FIRM Attorney for Plaintiff and Counter-Defnedant EMPLOYERS MUTUAL CASUALTY COMPANY

          Tyson E. Hafen DUANE MORRIS LLP Attorneys for Defendants/Cross-Defendants CATLIN SPECIALTY INSURANCE COMPANY, GREENWICH INSURANCE COMPANY, and XL INSURANCE AMERICA, INC.

          Ramiro Morales MORALES, FIERRO & REEVES Attorneys for Defendant/Counter-Claimant/Cross-Claimant ZURICH AMERICAN INSURANCE COMPANY

          STIPULATION AND PROTECTIVE ORDER

         Plaintiff and Counter-Defendant Employers Mutual Casualty Company (“EMC”), Defendant, Counter-Claimant and Cross-Claimant Zurich American Insurance Company (“Zurich”), and Defendants and Cross-Defendants Catlin Specialty Insurance Company, Greenwich Insurance Company and XL Insurance America, Inc. (collectively “Catlin/XL”) by and between their respective counsel, hereby stipulate as follows:

         1. The following definitions shall apply to this Protective Order:

1.1 “Action” refers to the above-captioned action entitled Employers Mutual Insurance Company v. Zurich American Insurance Company, et al., No. 2:18-cv-00089, which is pending in the United States District Court for the District of Nevada.
1.2 “Underlying Claim” shall mean the claims asserted by Pro Petroleum, Inc. against Strobel Construction Unlimited and/or Corrpro Companies, Inc. regarding the construction of the fuel storage tank facility, including the Cathodic Protection System, located at 4985 Sloan Drive in Las Vegas, Nevada.
1.3 “Confidential Information” shall mean: (1) information pertaining to the the Underlying Claim that are protected by one or more privileges, including but not limited, the attorney-client privilege, the attorney work product doctrine and/or the mediation privilege; (2) non-public insider information, personnel files, financial information, confidential commercial information, proprietary information, or other confidential or sensitive information which the producing party determines in good faith should be kept confidential; and (3) information that the producing party is under a duty to preserve as confidential under an agreement with or obligation to another. All Confidential Information produced pursuant to this Order shall be labeled “CONFIDENTIAL” by the producing party.

         2. All Confidential Information produced by any party in this Action shall be used only for purposes of the prosecution, defense or settlement of this Action and on appeal, if any, and for no other purpose whatsoever. No. Confidential Information shall be produced to or information therein disclosed to any party in this Action unless that party's counsel agrees to this Order.

         3. Except as set forth herein, the parties in this Action shall maintain the Confidential Information, all copies thereof, and any summaries, copies, abstracts, charts or notes made therefrom, and any facts or information contained therein or derived in whole or in part therefrom, in the strictest confidence. The parties in this Action may disclose the Confidential Information only to the Court and its personnel and/or to:

3.1 Counsel for the parties hereto and their agents;
3.2 Employees, paralegal assistants, or other secretarial and clerical employees or agents of such counsel;
3.3 Outside experts, consultants, and other independent contractors (and their employees or clerical assistants) who are employed, retained or otherwise contacted or consulted by the party to assist in any way in the preparation and trial of this Action and/or settlement;
3.4 Persons who are being prepared by counsel to give testimony at a deposition, or ...

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