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Allied World Surplus Lines Insurance Co. v. Premera

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

December 12, 2017

ALLIED WORLD SURPLUS LINES INSURANCE COMPANY F/K/A DARWIN SELECT FNSURANCE COMPANY; AND ALLIED WORLD SPECIALTY FNSURANCE COMPANY F/K/A DARWFN NATIONAL ASSURANCE COMPANY, Plaintiffs,
v.
PREMERA, Defendant. PREMERA, Counterclaim Plaintiff,
v.
ALLIED WORLD SURPLUS LINES FNSURANCE COMPANY F/K/A DARWFN SELECT FNSURANCE COMPANY; AND ALLIED WORLD SPECIALTY FNSURANCE COMPANY F/K/A DARWFN NATIONAL ASSURANCE COMPANY; LEXFNGTON FNSURANCE COMPANY; BCS FNSURANCE COMPANY; HOMELAND INSURANCE COMPANY OF NEW YORK; IRONSHORE SPECIALTY FNSURANCE COMPANY; RLI FNSURANCE COMPANY; TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA; AND RSUIFNDEMNITY COMPANY Counterclaim Defendants

          Bryan C. Graff, Ryan, Swanson & Cleveland, PLLC Carlton Fields Jorden Burt, P.A. Steven J. Brodie, pro hac vice Heidi Hudson Raschke, pro hac vice Attorneys for Plaintiffs/Counterclaim Defendants, Allied World Surplus Lines Insurance Company F/K/A Darwin Select Insurance Company; and Allied World Specialty Insurance Company F/K/A Darwin National Assurance Company

          John R. Neeleman, Gwendolyn C. Payton Kilpatrick Townsend & Stockton LLP Attorneys for Defendant/Counterclaim Plaintiff Premera

          Eliot Harris, Rodney Umberger, Williams Kastner & Gibbs PLLC David Boyer, D'Amato & Lynch, LLP Mary Jo Barry, pro hac vice MaryAnn Taylor, pro hac vice Attorneys for Ironshore Specialty Insurance Company

          Jeremy Roland Schulze, Lawrence Gottlieb, Betts Patterson & Mines Shipman & Goodwin Alexander R. Karam, pro hac vice Douglas M. Mangel, pro hac vice Attorneys for RLI Insurance Company

          Joseph D. Hampton, Betts Patterson & Mines Kaufman Borgeest & Ryan LLP Andrew Oldis, pro hac vice Matthew M. Collibee, pro hac vice Wayne E. Borgeest, pro hac vice Joan Gilbride, pro hac vice Attorneys for Travelers Casualty and Surety Company of America

          Alfred E. Donohue, Wilson Smith Cochran Dickerson Kerns, Frost & Pearlman, LLC Marc Pearlman, pro hac vice Attorneys for BCS Insurance Company

          Everett W. Jack, Jr., Nancy A. Brownstein, Davis Wright Tremaine LLP Attorneys for Lexington Insurance Company

          Robert J. Guite, Sheppard Mullin Richter & Hampton Attorneys for Homeland Insurance Company of New York

          Jennifer L. Crow, Scheer Law Group LLP Attorneys for RSUI Indemnity Company

          STIPULATED PROTECTIVE ORDER

          The Honorable Robert S. Lasnik, United States District Judge.

         1. PURPOSES AND LIMITATIONS

         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 ("Order"). The parties acknowledge that this Order is consistent with Local Civil Rule 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 does not presumptively entitle parties to file confidential information under seal.

         2. "CONFIDENTIAL MATERIAL"

         "Confidential Material" shall include the. following documents and tangible things produced or otherwise exchanged: trade secrets, business strategies and techniques, business policies and practices, financial information, results or projections, pricing proposals, contractual arrangements, arrangements with employees, proposed products, other business plans, confidential research, development or commercial information, or material that is otherwise considered confidential under applicable law in the parties' files. Confidential Material may also include documents and tangible things, whether handwritten or mechanically prepared in paper documents, microfilms, microfiche, computer tapes, computer disks (hard disks, floppy disks and CD ROM disks), computer printouts, or any other computer storage facility or system, audio or video tapes, produced or otherwise exchanged, interrogatory answers, responses to requests for admission, deposition transcripts and exhibits, pleadings, motions, affidavits, briefs and summaries of confidential information or documents that quote, summarize, or contain material entitled to protection.

         3. SCOPE

         The protections conferred, by this Order cover not only Confidential Material (as defined above) produced by the Parties or non-parties in this action, 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. However, the protections conferred by this Order 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 Order. 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 Order.

         4.2 Disclosure of "Confidential Material."

         Unless otherwise ordered by the Court or permitted in writing by the designating party, a receiving party may disclose Confidential Material only to:

(a) the receiving party's counsel of record in this action, as well as employees (including support staff) and agents of counsel to whom it is reasonably necessary to disclose the Confidential Material for this litigation ...

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