Nazimuddin Hashim v. New York Life Insurance Company et al

Filing 19

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal, re: Stipulation for Protective Order, 18 . Notice changes made by the court. See attach order for further details. (mz)

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MARTIN E. ROSEN(SBN 108998)
mrosen mail.hinshawlaw.com
MIC
L A.S. NEWMAN(SBN 205299)
mnewman mail.hinshawlaw.com
RICHARD . HOPKINS II(SBN 190108)
rhopkins mail.hinshawlaw.com
HINSHA & CULBERTSON LLP
633 West 5th Street 47th Floor
Los Angeles, CA 9x071-2043
Telephone: [phone]
Facsimile: 213-614-7399

FILED
CLEH'r: V.j [)ISTF!Cl COURT

MAR3Q2017
CENTnAL i5TRIGT U~ Cu!
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COTE CHA~JGES ~~~,^~E ~Y THE CG`'s ~T

7 Attorneys for Defendant
New York Life Insurance Company
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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NAZIMUDDIN HASHIM,

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Case No. 2:16-cv-07824-DMG-SS
(
Honorable Dolly M. Gee)

Plaintiff,
vs.

14 NEW YORK LIFE INSURANCE
COMPANY,AND DOES 1 THROUGH
15 10,
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]ORDER ON
OINT STIPULATION OF
CONFIDENTIALITY

Defendants.

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[Referred to N~gi.st.i ~a ~
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Suzanne H. 5ega1]"

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MINSHAW b CULBERTSON
633 West 5th Street, 47th Floor
Los Mgeles, CA 90071-2043
213-680-2800

~r

6gED]ORDER ON JOINT STIPULATION OF CONFIDENTIALITY
Case No. 2:16-cv-07824-DMG-SS

1 36189950x1 0986218
36266096x1 0991231

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Good cause having been shown within the parties' Stipulation of

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Confidentiality of documents to be produced in this action (the "Stipulation"), the

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Court hereby orders that the handling of confidential, proprietary and/or trade secret

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documents or information in this case shall be governed by the terms ofthe

7 Stipulation pS a~, i~r~_ ~;~,
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IT IS SO ORDERED.
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DATED:

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By:

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nite tates
the Central District of California

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All future
discover
include the
all
followinil~~~~ ~~
Iarlguag~
on the cover g

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page:
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[Referred to Ma g
Suzanne H. istrate Judge
Segal]~~

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HINSHAW b CULBERTSON
633 West 5th Street, 47th Floor
Los Mgeles, CA 90071-204]
21]-680-2800

ER ON JOINT STIPULATION OF CONFIDENTIALITY
Case No. 2:16-cv-07824-DMG-SS

1 36189950v10986218
36266096v1 0991231

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MARTIN E. ROSEN(SBN 108998)
mrosen mail.hinshawlaw.com
MICHA L A.S. NEV~JMAN(SBN 205299)
mnewman mail.hinshawlaw.com
RICHARD . HOPKINS II(SBN 190108)
r~h~~o~ pkins mail.hinshawlaw.com
HINSHA & CULBERTSON LLP
633 West 5th Street 47th Floor
Los Angeles, CA 9071-2043
Telephone: [phone]
Facsimile: 213-614-7399

7 Attorneys for Defendant
New York Life Insurance Company
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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NAZIMUDDIN HASHIM,

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Plaintiff,
vs.

14 NEW YORK LIFE INSURANCE
COMPANY,AND DOES 1 THROUGH
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Defendants.

Case No. 2:16-cv-07824-DMG-SS
(
Honorable Dolly M. Gee)
JOINT STIPULATION OF
CONFIDENTIALITY

COTE CHAF`~GES MADE BY THE COURT

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HINSHAW 8 CULBERTSON
633 West 5th Street, 47th Floor
Los Mgeles, CA 90071-2043
213-680-2800

JOINT STIPULATION OF CO
D~NT
ITY
Case No. 2:16-cv-078 4-DMG-SS
36266094v1 0991231

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TO THE HONORABLE DOLLY M. GEE AND HER COURT CLERK:

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WHEREAS,Defendant New York Life Insurance Company("New York

4 Life" or "Defendant"), per the Court's Scheduling Order, is prepared to produce
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confidential and proprietary claim manual documents to Nazimuddin Hashim

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"Hashim")("Hashim" and "Defendant" referred to herein as "the Parties") in the
7 above-captioned action;
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NOW THEREFORE,IT IS HEREBY STIPULATED AND AGREED as

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ollows:
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1.

The confidential and/or proprietary claims manual documents and other

confidential documents, or any portion thereof, to be produced by Defendant in this

12 action which are not publicly available, and which are designated by Defendant as
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Confidential," shall be deemed "Confidential Information."
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Designation ofthe documents as "Confidential" shall be made by

stamping each page comprising any such document, copy, or excerpt thereof with

16 the legend "CONFIDENTIAL" or a substantially similar legend at the time of
17 production.
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3.

Defendant may designate the documents, or any portion thereof,

including the contents and information therein, as protected under this Stipulation

20 and Order. If Hashim disagrees with any such designation, the Parties will attempt
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>
p v~~Jccr~.t ~ra pro(~cf~v~es ~r ~~~!f'YL

to resolve the dispute in good faith
-~
lam% ~ mac. 1~-vt-e- 3 ,

,
.Until such time as the dispute is

resolved, the Parties will treat the documents at issue as deemed Confidential under

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2 this stipulation.
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"Qualified Person" as used herein means:(i) members, employees,

2 counsel, consultants, experts, co-counsel, or anyone else deemed by Defendant to be
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HINSXAW b CULBERTSON
633 West 5th Stree[, 47M Floor
Los Mgeles, CA 90071-2043
213-680-2800

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JOINT STIPULATION OF CONFIDENTIALITY
Case No. 2:16-cv-07824-DMG-SS
36266094v1 0991231

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necessary for the preparation ofthe case,(ii) Hashim, and,(iii) this Court and its

2 personnel.
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5.

The Confidential Information, or any portion thereof, may only be

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disclosed to Qualified Persons and then only to the extent counsel in good faith

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believes• that such disclosure i reasonably necessary to the prosecution or defense

6 ofthis litigation.
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Each Qualified Person will maintain the Confidential Information, or

any portion thereof, in confidence and will not reveal it to anyone who is not a

9 Qualified Person without the prior written consent of Defendant's counsel, or in the
10 absence ofsuch consent, an order ofthe Court authorizing such disclosure.
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If either party wishes to use the Confidential Information, or any

12 portion thereof, during any discovery, motion practice, or trial of this action, the
13 Parties will, in advance, confer in good faith to agree upon a method
• tect such
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14 Confidential Information.
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8.

The disclosure of the Confidential Information, or any portion thereof,

17 to a Qualified Person without designating it as Confidential shall not constitute a
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waiver of the producing party's right to designate such information as Confidential

19 at a later time and, if so designated, the information shall thenceforth be treated as
20 Confidential subject to all terms of this Stipulation and Order.
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ocumen s i e wi
the cis ofthe

ual shall be filed under seal and

under seal until further

possible,

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At the conclusion ofthis lawsuit(including appeals, if any), the

2 Confidential Information, or any portion thereof, in the possession of any Qualified
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27 Person or any other person who has received such information pursuant to this
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MINSHAW d CULBERTSON
633 West 5th Street, 47M Floor
Los Mgeles, CA 90071-2043
213-680-2800

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JOINT STIPLTI,ATION OF CONFIDENTIALITY
Case No. 2:16-cv-07824-DMG-SS
36266094v1 0991231

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Stipulation and Order, together with all copies, extracts, and summaries thereof,

2 shall either be returned to the party that produced it, or it shall be destroyed. No
3 Confidential Information may be used in any other judicial or other proceeding or
4 f any other purpose whatsoever, except(i) where required by legal process or by
or
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law for lawful purposes, or (ii) upon the written consent of the producing party.
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This Stipulation and Order may be modified by a further Stipulation so

7 ordered by the Court or, ifthe Parties are unable to agree, by the Court on the
8 application of a party. This Stipulation and Order shall be binding upon all Qualified
9 Persons

.and any violation

10 thereof may be punishable by contempt.
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he parties agree t at even if the Court

12 Proposed Order hereto, t e
13 of this StiPulation as a se arate a
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will be

snot sign and enter the

nd by all ofthe terms and conditions

forcea

contract between t

rties.

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IT IS SO STIPiTLATED.

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~ DATED: March 24, 2017

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HINSHAW & CULBERTSON LLP
By: /s/Martin E. Rosen

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NIICHAEL S. NEVVMAN
Attorneys for Defendant
New York Life Insurance Company

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DATED: March 24, 2016

By: DONAHUE & HORROW
/
s/Michael Horrow
MICHAEL HORROW
ELIZABETH FLEMNIING
Attorneys for Plaintiff
Nazimuddin Hashim

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MINSHAW 8 CULBERTSON
633 Wesl 5th Street, 47th Floor
Los Mgeles, CA 90071-2043
213-6802800

JOINT STIPULATION OF CONFIDENTIALITY
Case No. 2:16-cv-07824-DMG-SS
36266094v1 0991231