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Hayes v. ATX Premier Insurance Co.

United States District Court, D. Nevada

July 15, 2019

KELLEY HAYES, Plaintiff,
v.
ATX PREMIER INSURANCE COMPANY; NATIONSBUILDERS INSURANCE SERVICES, INC.; DMA CLAIMS MANAGEMENT, INC., Defendants.

          CRAIG J. MARIAM, ESQ. Nevada Bar No. 10926 ROBERT E. SCHUMACHER, ESQ. Nevada Bar No. 7504 WING YAN WONG, ESQ. Nevada Bar No. 13622 DANIEL D. O'SHEA, ESQ. Admitted Pro Hac Vice GORDON REES SCULLY MANSUKHANI, LLP Attorneys for DMA Claims Management, Inc.

          Lawrence E. Mittin, Esq. Nevada Bar No. 5428 Attorneys for Kelley Hayes

          WILSON ELSER, MOSKOWITZ, EDELMAN & DICKER LLP John H. Podesta, Esq. Nevada Bar No. 7487 Attorneys for Nationsbuilders Insurance Services, Inc. and ATX Premier Insurance Company

          Honorable Gloria M. Navarro Judge.

          PROPOSED STIPULATED PROTECTIVE ORDER

          Nancy J. Koppe Magistrate Judge.

         TO THIS HONORABLE COURT:

         IT IS HEREBY STIPULATED by and between Kelley Hayes, Nationsbuilders Insurance Services, Inc., ATX Premier Insurance Company, and DMA Claims Management, Inc. (collectively, the “parties”), through their respective counsel of record, that this [Proposed] Stipulated Protective Order (“Protective Order”) shall govern all information and documents disclosed or produced in this case, including information and documents that may be or was disclosed or produced before this Protective Order is entered by the Court.

         WHEREAS the parties to this case may be required to disclose to the other certain sensitive, personal, financial, confidential and/or proprietary information and documents relating to the subject matter of this litigation, the unauthorized use or disclosure of which is likely to cause harm to the party producing such information or contravene an obligation of confidentiality to a third person or to a court.

         Accordingly, the parties hereby stipulate to and petition the Court to enter the Protective Order, pursuant to Fed.R.Civ.P. 26(c). The parties acknowledge that this Protective Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled to treatment as confidential under applicable state or federal law. The parties further acknowledge that this Protective Order creates no entitlement to file confidential information under seal; the parties shall follow the applicable rules when seeking permission from the Court to file material under seal. The parties respectfully request that this Court enter the Stipulated Protective Order on the following terms:

         A. DEFINITIONS

         The following Definitions shall apply in this Order:

         1. The term “Confidential Information” will mean and include information contained or disclosed in any materials that is deemed to be Confidential Information by any party to which it belongs.

         2. The term “Materials” will include, but is not limited to: documents; correspondence; memoranda; financial information; email; marketing plans; marketing budgets; customer information; materials that identify customers or potential customers; price lists or schedules or other matter identifying pricing; minutes; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; forecasts; notes of conversations; desk diaries; appointment books; videos; expense accounts; recordings; photographs; sketches; drawings; business reports; disclosures; and internet archives.

         3. The term “Counsel” will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff.

         B. LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL INFORMATION

         The following provisions shall apply in this litigation:

         1. Each party to this litigation that produces or discloses any Materials, written discovery, transcripts or trial or deposition testimony, or information the producing party believes should be subject to this Protective Order may designate the same as “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.”

         (a) Designation as “CONFIDENTIAL”: Any party may designate information as “CONFIDENTIAL” only if, in the good faith belief of such party and its Counsel, the unrestricted disclosure of such information could be harmful to the business or operations of such party.

         (b) Designation as “CONFIDENTIAL - FOR COUNSEL ONLY”: Any party may designate information as “CONFIDENTIAL - FOR COUNSEL ONLY” only if, in the good faith belief of such party and its Counsel, the information is among that considered to be most sensitive by the party, including but not limited to trade secret or other confidential research, development, financial, customer related data or other ...


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