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Naxos, LLC v. American Family Insurance Co.

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

August 5, 2019

NAXOS, LLC, d/b/a Spiros Greek Restuarant, Plaintiff,
v.
AMERICAN FAMILY INSURANCE COMPANY, a foreign insurer, Defendant.

          Thomas Lether, WSBA #18089 EricNeal, WSBA#31863 Attorneys for Plaintiff LETHER & ASSOCIATES, PLLC

          William C. Smart, WSBA #8192 Ian S. Birk, WSBA #31431 Nathan L. Nanfelt, WSBA #45273 Attorneys for Plaintiff KELLER ROHRBACK L.L.P.

          Rory W. Leid, III, WSBA #25075 Jeremy L. Muth, WSBA #52055 Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER [PROPOSED]

          JAMES L. ROBART, JUDGE

         1. PURPOSES AND LIMITATIONS

         Discovery in this action may involve production of documents which a party may deem to be 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 may include, such documents as a party designates confidential.

(a) It is anticipated that American Family Insurance Company ("American Family") will designate the following documents:
i. American Family's claims manuals;
ii. American Family's course and training materials; and
iii. American Family's confidential and proprietary information that may be included within documents produced pursuant to Plaintiffs' discovery requests.
(b) It is anticipated that Naxos, LLC ("Naxos") will designate the following documents:
i. Naxos' confidential and propriety information that may be included within documents produced pursuant to discovery requests.

         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. 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 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 ...


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