United States District Court, W.D. Washington, Seattle
NATIONAL FROZEN FOODS CORPORATION, a Washington corporation, Plaintiff,
BERKLEY ASSURANCE COMPANY, an Iowa corporation, Defendant.
TILDEN THOMAS & CORDELL LLP Attorneys for Plaintiff
National Frozen Foods Corporation Dale L. Kingman, WSBA
#07060 Greg D. Pendleton, WSBA #38361
BREITMAN LLP Attorneys for Defendant Berkley Assurance
Company Peter J. Mintzer, WSBA #19995 Justin S. Landreth,
WSBA #44849 Selman Breitman LLP
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
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:
documents containing confidential and proprietary information
relating to finances, marketing, sales, production, clients,
customers, and testing; and
non-public communications and documents relating to the pea
recall and Italian Green Bean recall.
documents relating to marketing, sales, claims handling
policies and procedures, and underwriting policies and
documents relating to insureds and prospective insureds other
than National Frozen Foods Corporation.
documents relating to policies, procedures, practices,
guidelines, or manuals concerning the brokering insurance;
documents relating to clients or prospective clients other