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Myers v. State Farm Mutual Automobile Insurance Co.

United States District Court, D. Nevada

April 10, 2019

JB MYERS, Plaintiff,
v.
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, a foreign corporation; and DOES I-X, inclusive; and ROE CORPORATIONS I-X, inclusive, Defendants.

          LEWIS BRISBOIS BISGAARD & SMITH LLP Robert W. Freeman, Esq. Nevada Bar No. 03062 Pamela L. McGaha, Esq. Nevada Bar No. 08181 Cheryl A. Grames, Esq. Nevada Bar No. 12752 Attorneys for Defendant State Farm Mutual Automobile Insurance Company

          LAW OFFICES OF ERIC R. BLANK, P.C. Eric R. Blank, Esq. Nevada Bar No. 6910 Darren J. Lach, Esq. Nevada Bar No. 9606 Bethany Kirkenir, Esq. Nevada Bar No. 13165 Attorneys for Plaintiff JB Myers

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         It appearing to the Court that the Plaintiff JB MYERS (“Plaintiff”) and Defendant STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (“State Farm”) (collectively, the “Parties”) agree that State Farm possesses proprietary policies and procedures that include confidential information that may be subject to discovery in the proceedings in this matter but which should not be made available to the public generally, this Court hereby orders that:

         1. This Confidentiality Agreement and Protective Order (“Order”) shall govern certain discovery and document production among the Parties, as well as discovery and document production from third parties, in the above-referenced action.

         2. For purposes of this Order, the term “Confidential Information” shall refer to: (1) information which any party or non-party believes in good faith to be a trade secret or confidential research, development, commercial, or other proprietary business information within the meaning of FRCP 26(c)(1)(G); and (2) documents and/or testimony that may reveal confidential, proprietary, personal or commercially sensitive information. Such Confidential Information may be contained in any written, printed, recorded, or graphic matter of any kind, and shall retain its confidential designation regardless of the medium on which it is produced, reproduced, or stored. Such Confidential Information may also be elicited at deposition or through written discovery.

         3. Whenever any party or non-party desires to designate information contained in a document as Confidential Information, the designating party shall mark each page of the document with the word “CONFIDENTIAL” and identify such Confidential Information at the time of production. Confidential Information may be used in the course of depositions in accordance with this Order.

         4. Transcripts or exhibits from any deposition or hearing shall be temporarily designated as “Confidential” and be treated as subject to the terms of this Order. Within forty-five (45) days of receipt of such transcripts and exhibits, Counsel will designate the pages of the transcripts or exhibits which shall remain designated as “Confidential” and will advise all other parties. If no designation is made within forty-five (45) days, the entire transcript and all exhibits will be deemed not confidential.

         5. All documents produced or information disclosed and any other records designated as “confidential” by State Farm shall be revealed only to:

a) Plaintiff;
b) Plaintiff's counsel of record in this case;
c) Defendant;
d) Defendant's counsel of record in this case;
e) Paralegals and secretarial employees under counsel's direct supervision;
f) Outside photocopying, translating, document management, and exhibit preparation services engaged by a party for ...

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