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County of Ventura v. National Union Fire Insurance Co.

September 23, 2009

COUNTY OF VENTURA, A NON-PROFIT GOVERNMENTAL ENTITY, PLAINTIFF,
v.
NATIONAL UNION FIRE INSURANCE COMPANY, A PENNSYLVANIA CORPORATION AND A SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP, AMERICAN HOME ASSURANCE, A PENNSYLVANIA CORPORATION AND A SUBSIDIARY OF AMERICAN INTERNATIONAL GROUP AND DOES 1 THROUGH 25, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Frederick F. Mumm Magistrate Judge of the U.S. District Court

[PROPOSED] JOINT STIPULATED PROTECTIVE ORDER

The Parties, by and through their respective attorneys of record, having STIPULATED and AGREED to the following and good cause appearing therefore, it is hereby

ORDERED as follows:

1. The parties and their counsel agree that all documents and information produced or provided by the parties in this action designated as "Confidential Information," shall be used only for purposes necessary to the evaluation, resolution and/or litigation of the claims which are the subject matter of this action, and not for any other purpose without further written agreement by the parties or order of the Court. This provision does not apply to any document or information which any party has obtained from legitimate sources outside of this litigation which pertains to this litigation (i.e., newspaper articles, court documents from other cases, etc.) or that they are or may be entitled to obtain through the litigation/discovery process.

2. It is agreed that documents or information relating to the claim files maintained by American Home Assurance and National Union including, but not limited to, medical reports and records concerning employees of the County of Ventura as well as proprietary, privileged and/or confidential materials prepared in connection with the defense of the County of Ventura's workers' compensation claims, may be marked as containing "Confidential Information" by Defendants National Union Fire Insurance Company of Pittsburgh, Pa. ("National Union") and American Home Assurance Company ("American Home"). The parties have the right to review these documents after they are produced with the "Confidential Information" designation. If, after review, either party disagrees with the "Confidential Information" designation, it has the right to move the Court for any order deeming the document non-confidential and asking that the designation be removed.

3. As indicated, the records requested for production pertain to claim files maintained by American Home and National Union including, but not limited to, medical reports and records concerning employees of the County of Ventura, as well as proprietary materials prepared in connection with the defense of the County of Ventura's workers' compensation claims. The parties agree that any disclosures in this case pertaining to documents otherwise privileged and subject to privacy laws and designated as "Confidential Information" pursuant to this Stipulated Protective Order will maintain confidentiality and will be precluded from dissemination outside the confines of this litigation.

4. The party receiving Confidential Information may not disclose or make available such Confidential Information to any person or persons, except to the following:

(a) The Court and court personnel;

(b) The parties;

(c) Counsel retained or employed by a party to the extent necessary for this action, including the necessary employees or agents of counsel to the parties assigned to and necessary to assist such counsel in this action;

(d) The risk manager and/or in-house counsel of the parties to the extent necessary for this action;

(e) Any court reporter or typist rendering services for recording or transcribing testimony in this action or any outside independent reproduction or graphics firm rendering reproduction or graphics services in this action;

(f) Expert witnesses or consultants retained by the parties or counsel, but only to the extent ...


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