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Wall v. Country Mutual Insurance Co.

United States District Court, W.D. Washington, Seattle

October 26, 2017

DANIEL WALL and CARI WALL, husband and wife, Plaintiffs,
v.
COUNTRY MUTUAL INSURANCE COMPANY, a foreign corporation, Defendant.

          IMPACT LAW GROUP THENELL LAW GROUP, P.C. Attorneys for Plaintiffs

          THENELL LAW GROUP, P.C. Daniel E. Thenell, WSBA # 37297 Daniel E. Thenell, WSBA # 37297 Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

          Marsha J. Pechman United States District Judge.

         1. PURPOSES AND LIMITATIONS

         This Stipulation is entered into by and between Plaintiffs Daniel Wall and Cari Wall and Defendant Country Mutual Insurance Company. The named parties possess certain confidential and/or proprietary information which may be disclosed to the other parties in this action, specifically, Country Mutual's Best Practices, the underwriting file, the agent file, and personal or business financial information. Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. “CONFIDENTIAL” MATERIAL

         Confidential material means any document, data, information, video, writing, paper, tangible thing, transcript of oral testimony, whether printed or recorded or reproduced by any other mechanical process, or written or produced by hand, and the content of any such document, which the party designates as “Confidential”. By way of example, and not limitation, confidential information may include or be included in documents, papers, drawings, diagrams, plans, specifications, manuals, transcripts, answers to Interrogatories and other responses to discovery requests, and any instruments which compromise, embody, or summarize matter which the party considers confidential and desires not be made public. At the time this Stipulation is entered into the parties have identified the following confidential information: Country Mutual's Best Practices, the underwriting file, the agent file, and personal or business financial information. The parties reserve the right to identify and designate additional confidential materials identified during the course of discovery.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material.

         Use of any information or documents labeled “Confidential” and subject to this Protective Order, including all information derived therefrom, shall be restricted solely to the litigation of this case and shall not be used by any party for any business, commercial, or competitive purpose.

         However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced ...

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