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Farmers Insurance Exchange v. Toto USA, Inc.

United States District Court, D. Nevada

August 2, 2018

FARMERS INSURANCE EXCHANGE, as subrogee of Doug Ansell, Plaintiff,
v.
TOTO USA, INC., a Georgia corporation; CHRISTOPHER HOMES, LLC, a Nevada company; DOES I - X, inclusive, and ROE CORPORATIONS I - X, inclusive, Defendants.

          Kenneth W. Maxwell, Paul T. Landis Attorneys for Plaintiff.

          Dale A. Hayes Jr. Attorney for Defendant Christopher Homes LLC.

          Daniel S. Rodman, Alexandria L. Layton, SNELL & WILMER L.L.P., Attorneys for Defendant TOTO USA, INC.

          STIPULATED PROTECTIVE ORDER

         IT IS STIPULATED and agreed by the parties to this action that, in order to facilitate discovery, in which the parties may request production of documents containing proprietary, trade secret and confidential information of Defendant TOTO USA, INC. (“Toto”) and related companies, that the following protective order shall be entered by the court.

         STIPULATED PROTECTIVE ORDER REGARDING THE CONFIDENTIALITY OF DOCUMENTS AND MATERIALS

         Pursuant to Federal Rule of Civil Procedure 26(c), the parties, in connection with the above-captioned action agree to the following Stipulated Protective Order to facilitate the exchange of discoverable information and, in particular, the production of documents, the service of discovery responses, and the taking of testimony. Unless modified pursuant to the terms contained in this Order, this Order shall remain in effect.

         1. Documents or information containing confidential or proprietary business information and/or trade secrets (“Confidential Information”) that bear significantly on the claims or defenses of defendant Toto is likely to be disclosed or produced during the course of discovery in this litigation;

         2. Toto asserts that public dissemination and disclosure of Confidential Information could severely injure or damage Toto and would place Toto at a competitive disadvantage; and

         3. Entry of an order controlling access to and dissemination of Confidential Information will protect the respective interests of the parties and facilitate the progress of disclosure and discovery in this case, THEREFORE, IT IS STIPULATED:

         1. Documents, discovery responses, and deposition testimony containing Confidential Information produced, served or given by Toto in this litigation are referred to as “Protected Documents.” Except as otherwise indicated below, all documents, discovery responses, or deposition testimony designated by Toto as “Confidential” upon production or containing Confidential Information and which are disclosed or produced to the attorneys for the other parties to this litigation are Protected Documents and are entitled to confidential treatment as described below.

         2. Protected Documents and any information contained therein shall not be used or shown, disseminated, copied, or in any way communicated to anyone for any purpose whatsoever, except as provided for below.

         3. Protected Documents and any information contained therein shall be disclosed only to the following persons (“Qualified Persons”):

(a) Counsel in this action for the party or parties receiving Protected Documents or any information contained therein;
(b) Employees of such counsel assigned to and necessary to assist such counsel in the preparation and trial of this action;
(c) Retained experts, advisors and consultants (including persons working for or with such experts, advisors and consultants) of the party or parties receiving Protected Documents (“Retained Experts”), to the extent necessary to perform their work in connection with this case; and
(d) The Court, Court personnel, and any Special Masters and/or Mediators appointed by the Court, under seal.

         Protected Documents and any information contained therein shall be used solely for use and in connection ...


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