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Williams v. Safeco Insurance Company of America

United States District Court, D. New Mexico

February 15, 2019

REBECCA WILLIAMS, Plaintiff,
v.
SAFECO INSURANCE COMPANY OF AMERICA, Defendant.

          Shannon A. Parden, Esq. RAY, McCHRISTIAN & JEANS, P.A. Attorneys for Defendant Safeco Insurance Co. of America

          Christopher P. Bauman Cynthia Weisman Bauman & Dow, P.C. Plaintiff's attorneys

          STIPULATED PROTECTIVE ORDER

          STEPHAN M. VIDMAR United States Magistrate Judge.

         To expedite the flow of discovery material, facilitate the prompt resolution of discovery disputes, and protect the confidentiality of certain documents produced and the information contained herein, the Court hereby orders as follows:

         1. Plaintiff Rebecca Williams (“Plaintiff”) and Defendant Safeco Insurance Company of America (“Safeco”), have sought discovery from each other or third parties, of certain documents and information that constitute confidential information. “Confidential Material, ” for purposes of this Order, may include documents disclosed or produced during discovery, deposition testimony and/or transcripts, and any portions of any pleadings or other documents that quote from or summarize the foregoing.

         2. The Parties may designate documents or information as Confidential Material. In the case of documents, such designation shall be made by stamping the word “Confidential” on all pages of the document. In the case of deposition testimony, such designation may be made by identifying on the record those portions of the testimony considered confidential, and such designation shall then be conspicuously identified by the reporter in the transcript as confidential. Additionally, in the case of deposition testimony, such designation may also be made upon review of the transcript following the deposition and asserted by means of written notice to the other parties identifying those portions of the testimony considered confidential. Computer disks, drives, programs, and other electronic media and non-documentary material may be designated as Confidential Material by any suitable, conspicuous means. The designation of information as Confidential Material shall constitute a certification by the attorney making the designation that he or she believes in good faith that the material is entitled to confidential protection.

         3. The Confidential Material shall not be disclosed to any persons other than:

A. the attorneys for the Parties, and paralegals and clerical staff (whether employees or independent contractors) who are assisting in the litigation;
B. officers, directors and/or employees of the Parties who have direct responsibility for assisting such counsel in the preparation and trial of the action;
C. court reporters, court officials, and the jury involved in this litigation;
D. experts, consultants and investigators and their staff who are retained by a party for purposes relating to this litigation and who have executed a confidentiality agreement in conformity with this Protective Order; and
E. any other non-party witnesses or deponents who have executed a confidentiality agreement in conformity with this Protective Order, or deponents who agree on the record to maintain the confidentiality of the material.

         4. The Confidential Material received by any of the persons in the categories listed above in paragraph 3 shall be used only for purposes of this litigation and for no other purposes, including for any other litigation, whether on the same issues in this case or others, or for any other business or personal purpose. Nothing in this Protective Order shall prevent the Parties from any use of their own Confidential Material. The Confidential Material may not be disclosed to the persons described in categories (D) and (E), above, unless the disclosing party determines in good faith that the disclosure is necessary for the purpose of developing testimony of such witness or deponent. The Confidential Material provided to a party shall be securely maintained in the offices of that party's outside counsel. Any recipient of the Confidential Material shall maintain such information in a secure and safe manner, and the recipient shall exercise due and proper care with respect to the storage, custody, access, and use of all such information. In addition, any summary or copy of information contained in the Confidential Material shall be subject to the terms of this Protective Order to the same extent as the information or document of which summary or copy is made, and must be clearly labeled as containing confidential information.

         5. The Confidential Material may be copied or reproduced only to the extent reasonably necessary for this litigation. All such copies or reproductions shall ...


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