United States District Court, W.D. Washington, Seattle
RUSHFORTH CONSTRUCTION CO., INC., d/b/a AP RUSHFORTH, a Washington corporation, Plaintiffs,
ARCH SPECIALTY INSURANCE COMPANY, a foreign insurance company; ENDURANCE AMERICAN SPECIALTY INSURANCE COMPANY, a foreign insurance company; SCOTTSDALE INSURANCE COMPANY, a foreign insurance company; JAMES RIVER INSURANCE COMPANY, a foreign insurance company; SENECA SPECIALTY INSURANCE COMPANY, a foreign insurance company; GEMINI INSURANCE COMPANY, a foreign insurance company; UNITED SPECIALTY INSURANCE COMPANY, a foreign insurance company; MITSUI SUMITOMO INSURANCE COMPANY OF AMERICA, a foreign insurance company; OHIO SECURITY INSURANCE COMPANY, a foreign insurance company; THE OHIO CASUALTY INSURANCE COMPANY, a foreign insurance company; NEW HAMPSHIRE INSURANCE COMPANY, a foreign insurance company; WESCO INSURANCE COMPANY, a foreign insurance company,, Defendants.
McCLURE Christopher J. Nye, WSBA No. 29690 Attorney for
Defendant Arch Specialty Insurance Company
NICOLAIDES FINK THORPE MICHAELIDES SULLIVAN, LLP Sara M.
Thorpe, Bar No. 146529 Attorney for Defendant Arch Specialty
| HAYES PLLC Gregory L. Harper, WSBA No. 27311 Thomas M.
Williams, WSBA No. 47654 Attorneys for Plaintiff, Rushforth
MOBERG & ASSOCIATES, P.S. Kara R. Masters, WSBA No. 23459
Jerry Moberg, WSBA No. 5282 Attorneys for Defendant, James
River Insurance Co.
SMITH COCHRAN & DICKERSON John M. Silk, WSBA No. 15035
Lisa C. Neal, WSBA No. 25686 Attorney for Defendants, Ohio
Security Insurance Co. and The Ohio Casualty Insurance Co.
LAW GROUP LLP Jonathan Dirk Holt, WSBA No. 28433 Kelsey L.
Shewbert, WSBA No. 51214 Attorneys for Defendant, United
Specialty Insurance Co.
BRISBOIS BISGAARD & SMITH LLP Gregory S. Worden, WSBA No.
24262 John T. Bender, WSBA No. 49658 Lane J. Ashley, Bar No.
073296 Attorneys for Defendant, Wesco Insurance Company
MORSE BAKER PLLC Steven D. Jensen, WSBA No. 26495 Gabriel
Baker, WSBA No. 28476 Attorneys for Defendant, New Hampshire
& ASSOCIATES, PLLC Thomas Lether, WSBA No. 18089 Eric
Neal, WSBA No. 31863 Attorneys for Defendant, Seneca
Specialty Insurance Company
BREITMAN LLP Peter J. Mintzer, WSBA No. 19995 Attorneys for
Defendant, Gemini Insurance Company
ARMSTRONG & FELTON LLP James P. Murphy, WSBA No. 18125
Tracy Y. Williams, WSBA No. 35239 Attorneys for Defendant,
Endurance American Specialty Insurance Company
STIPULATED PROTECTIVE ORDER
HONORABLE JOHN C. COUGHENOUR, JUDGE
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
• Claim file documents which reflect or refer to rate
information, reserves, attorney-client privileged
communications, or work product relating to the defense of
Rushforth, and/or other competitive business information.
• Documents reflecting insurer procedures and