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Brian Wiegand, An Individual v. State Farm Life Insurance Company and Does 1 Through 50

May 7, 2013

BRIAN WIEGAND, AN INDIVIDUAL,
PLAINTIFF,
v.
STATE FARM LIFE INSURANCE COMPANY AND DOES 1 THROUGH 50, INCLUSIVE, DEFENDANTS.



STIPULATION AND PROTECTIVE ORDER COMPLAINT FILED: July 19, 2012 TRIAL DATE: July 22, 2014

Plaintiff Brian Wiegand ("Plaintiff") and Defendant State Farm Life Insurance Company ("Defendant"), by and through their respective counsel, hereby stipulate and agree as follows:

WHEREAS, the parties to this proceeding anticipate that during the course of the above-captioned litigation, the parties will produce or provide documents and information (including electronic data), which one or more parties contend contain trade secrets or other sensitive, private, confidential or proprietary information, including but not limited to:

(a) Defendant's business operations, including, but not limited to, information about Defendant's applicants, hiring practices, organizational structure, policies, programs, methods and/or procedures, practices, or other information and documentation which may provide insight into the day-to-day processes and procedures utilized by Defendant; and/or

(b) Plaintiff's private information, including employment, financial, personal or medical information;

WHEREAS, the parties to this proceeding have a particularized need of a Court Order as to each category of information listed above in order to protect Defendant's business operations from being revealed to its competitors and so that third-party private information is not released to the public;

WHEREAS, the parties to this proceeding have a particularized need of a Court Order relating to other sensitive, private, confidential or proprietary information because the parties expect that some or all of this information may be used in motion practice, including dispositive motion practice, and should be sealed prior to filing. A private agreement would not be sufficient to ensure that the sensitive, private, confidential or proprietary information is protected from such disclosure;

THEREFORE, the parties seek the entry of an Order, pursuant to Federal Rule of Civil Procedure 26(c) and Local Rule 141.1(b), (c), governing the disclosure of documents and information therein pertaining to "Confidential Information" or "Counsel Only" information on the terms set forth herein.

IT IS HEREBY AGREED, STIPULATED AND ORDERED THAT:

1. In connection with discovery and other proceedings in this action, the parties may designate any document, thing, material, testimony or other information derived therefrom, as "Confidential Information" under the terms of this Stipulated Protective Order ("Order"). Neither party shall designate any discovery material as "Confidential Information" without first making a determination that the information is properly subject to protection under Fed. R. Civ. P. 26(c) and that such protection is warranted in good faith. "Confidential Information" shall not be disclosed except as provided for herein.

2. Designations of "CONFIDENTIAL" materials. The Parties shall have the right to designate as "CONFIDENTIAL," and this Protective Order shall only apply to, any information or documents that are:

(a) Defendant's business operations, including, but not limited to, information about Defendant's applicants, hiring practices, organizational structure, policies, programs, methods and/or procedures, practices, or other information and documentation which may provide insight into the day-to-day processes and procedures utilized by Defendant; and/or

(b) ThePlaintiff's private information, including personnel, employment, financial, personal, or medical information.

3. Designation of Deposition Testimony as "CONFIDENTIAL." With respect to deposition testimony, the designation of confidentiality may be made on the record at the time of the deposition, at which time the testimony shall be subject to the full protection of this Order. In the case of testimony not so designated during the course of a deposition, counsel may, within ten (10) days of receipt of the deposition transcript, notify the Parties that the deposition testimony contains confidential material, in which case the designated testimony shall be subject to the full protections of this Order.

4. No information or things designated "CONFIDENTIAL" shall be disclosed by any Party, except as set forth in this Protective Order. No Party shall use any material designated "CONFIDENTIAL" for any purpose other than in connection with preparation and trial of this action. No copies of designated materials shall be made, except by or on behalf of counsel of record ...


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