Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Takashi v. Allstate Insurance Company and Does 1 Through 100

December 22, 2011

TAKASHI NAKAMURA AND TOSHIKO NAKAMURA, PLAINTIFFS
v.
ALLSTATE INSURANCE COMPANY AND DOES 1 THROUGH 100, INCLUSIVE, DEFENDANT.



The opinion of the court was delivered by: Honorable John E. McDermott United States Magistrate Judge

The Hon. R. Gary Klausner Courtroom 850

STIPULATED CONFIDENTIALITY AGREEMENT AND [PROPOSED] ORDER

Complaint Filed: February 17, 2011 Trial Date: March 6, 2012

WHEREAS, defendant Allstate Insurance Company has in its possession DOCUMENTS,*fn1 including but not limited to claim handling and underwriting manuals, which it contends contains confidential and/or proprietary information, that have been requested in discovery during the course of this litigation; and

WHEREAS, the parties to this action desire to avoid controversy regarding the potential disclosure of said DOCUMENTS;

WHEREAS GOOD CAUSE EXISTS to protect said DOCUMENTS because they contain confidential and/or proprietary information that if disclosed outside the context of this litigated matter would unduly prejudice Allstate not only because they could be improperly used against it in other litigated matters but also because competitors could appropriate Allstate's proprietary information for their own use and/or to Allstate's detriment in the competitive marketplace.

THUS, IT IS HEREBY STIPULATED AND AGREED by and between the parties to this action, through their respective counsel of record that:

1. Allstate will make available for inspection and copying confidential and/or proprietary DOCUMENTS:

1.1 The non-privileged portions of the Claim Policy Practices Procedures Manual, dated October 17, 2003, with revisions, and privilege log;

1.2 Allstate 1992 Homeowner Manual;

1.3 Storm Issues (Z082709) (9/03/09);

1.4 Storm Issues (Z082709) (9/05/09);

1.5 Storm Issues (Z082709) (9/05/09);

1.6 Storm Issues (Z082709) (9/05/09);

1.7 Staff Operational Guide (05/19/09);

1.8 Staff Operational Guide (05/19/09);

1.9 Staff Operational Guide (05/19/09);

1.10 Staff Operational Guide (10/22/09);

1.11 Staff Operational Guide (02/25/10);

1.12 Staff Operational Guide (05/05/10);

1.13 Staff Operational Guide (05/05/10);

1.14 Staff Operational Guide (05/27/10);

1.15 Staff Operational Guide (09/01/10);

1.16 Staff Operational Guide (09/01/10);

1.17 Staff Operational Guide (10/22/10);

1.18 Staff Operational Guide (10/22/10);

1.18 Staff Operational Guide (01/11/11);

1.19 State Issues California ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.