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National Frozen Foods Corp. v. Berkley Assurance Co.

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

July 27, 2018

NATIONAL FROZEN FOODS CORPORATION, a Washington corporation, Plaintiff,
v.
BERKLEY ASSURANCE COMPANY, an Iowa corporation, Defendant.

          GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Plaintiff National Frozen Foods Corporation Dale L. Kingman, WSBA #07060 Greg D. Pendleton, WSBA #38361

          SELMAN BREITMAN LLP Attorneys for Defendant Berkley Assurance Company Peter J. Mintzer, WSBA #19995 Justin S. Landreth, WSBA #44849 Selman Breitman LLP

          MOUND COTTON WOLLAN & GREENGRASS LLP Attorneys for Defendant Berkley Assurance Company Jeffrey S. Weinstein* Diana McMonagle* *Admitted Pro Hac Vice

          ANDREWS SKINNER, P.S. Attorneys for Defendants AmWINS Brokerage of Illinois, AmWINS Brokerage of Arizona, and AmWINS Group, LLC Stephen G. Skinner, WSBA #17317 Alison L. Markette, WSBA #46477

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF 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. 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 shall include the following documents and tangible things produced or otherwise exchanged:

         For NFF:

         a. documents containing confidential and proprietary information relating to finances, marketing, sales, production, clients, customers, and testing; and

         b. non-public communications and documents relating to the pea recall and Italian Green Bean recall.

         For Berkley:

         a. documents relating to marketing, sales, claims handling policies and procedures, and underwriting policies and guidelines; and

         b. documents relating to insureds and prospective insureds other than National Frozen Foods Corporation.

         For AmWINS Defendants:

         a. documents relating to policies, procedures, practices, guidelines, or manuals concerning the brokering insurance; and

         b. documents relating to clients or prospective clients other than ...


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