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Hartford Fire Insurance Co. v. Lexington Insurance Co.

United States District Court, D. Nevada

April 23, 2019

HARTFORD FIRE INSURANCE COMPANY Plaintiff,
v.
LEXINGTON INSURANCE COMPANY Defendant.

          HOLLY S. PARKER (SBN 10181) RYAN W. LEARY (SBN 11630) LAXALT & NOMURA, LTD. Attorneys for Plaintiff, Hartford Fire Insurance Company

          Karmon & Graham, P.A. Susan M. Hogan Counsel for Plantiff Hartford Fire Insurance Company

          Andrew D. Herold (SBN 7378) Nicholas B. Selerno (SBN 6118) Consel for Defendant Insurance Company

          STIPULATION FOR JOINT PROTECTIVE ORDER

         Plaintiff and Defendant, by and through their respective counsel of record, hereby stipulate to the following Joint Protective Order, subject to the approval by the Court.

         1. Purpose.

         It is recognized that certain information likely to be produced and discussed in this litigation deserves protection under Federal Rule of Civil Procedure 26(c) because the information may contain confidential, personal, commercial, or financial information which is proprietary in nature and therefore deserving of protection from disclosure and dissemination. This Protective Order is intended to govern the use and dissemination of this confidential information which may be contained in documents and discovery material produced by the parties, whether informally or formally in response to interrogatories, requests for admissions, requests for production of documents, or obtained or submitted to the Court through affidavit, designated record or other testimony, including deposition testimony, or otherwise obtained or submitted in this action.

         2. Definition of Confidential Information.

         Confidential information shall be designated as such at time of production or as soon as practicable and should be limited to any information which a party reasonably and in good faith believes to contain or disclose confidential, or proprietary personal or business information of the party or of a third party, that could not be independently obtained, and/or confidential, personal or business information, the disclosure of which might reasonably pose a commercial disadvantage to the owner or custodian of the information.

         3. Limitation on Designation of Information.

         The parties shall only designate information that is confidential if they have a reasonable and good faith belief that the information should, in fact, be so designated. If the Court later determines that the parties did not act reasonably or in good faith in making such a designation, the Court shall award to the party opposing the designation that party's reasonable attorneys' fees in disputing the designation; provided, however, that no party may challenge such a designation unless and until that party has first made a reasonable good faith attempt to resolve the matter informally with the designating party.

         4. Method of Document Designation.

         Documents containing Confidential Information may be so designated at the point of production or as soon thereafter as is practical.

         5. Designation of Deposition Testimony.

         Deposition testimony that the parties reasonably believe will contain Confidential Information shall only be taken in the presence of the persons entitled to such information under this Order. Where practical, the record shall identify those portions which relate to Confidential Information and that information will be identified as such at the time the deposition is taken. At the request of the party claiming confidentiality, the parties may make arrangements with the court reporter so that the portion of the transcription in question can be separately bound and labeled as confidential.

         6. Method of Exhibit Designation.

         Exhibits introduced at a deposition that contain Confidential Information may be so designated by making a statement to that effect on the record at the time of their introduction. Exhibits designated as containing Confidential Information shall be placed in sealed containers and/or filed under seal prior to being placed in the Court file or otherwise placed in the public record. At the request of the party claiming confidentiality, the exhibits designated as containing Confidential Information shall be placed in ...


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