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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1 2 3 4 5 6 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: 213-680-2800 Facsimile: 213-614-7399 FILED CLEH'r: V.j [)ISTF!Cl COURT MAR3Q2017 CENTnAL i5TRIGT U~ Cu! ~rOHiJiA : ~v __ ~~r~ury COTE CHA~JGES ~~~,^~E ~Y THE CG`'s ~T 7 Attorneys for Defendant New York Life Insurance Company 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 NAZIMUDDIN HASHIM, 12 13 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, 16 ]ORDER ON OINT STIPULATION OF CONFIDENTIALITY Defendants. 17 18 19 2 0 ~~ ~ ~ir~_c1 u~ , ~ „~~ ~.~ . on t1~1c~ c~~v~. _ " [Referred to N~gi.st.i ~a ~ ~~ ,~,_ Suzanne H. 5ega1]" 21 2 2 23 24 25 2 6 27 28 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 J _ _ _' _ _ v 1 2 3 Good cause having been shown within the parties' Stipulation of 4 Confidentiality of documents to be produced in this action (the "Stipulation"), the 5 Court hereby orders that the handling of confidential, proprietary and/or trade secret 6 documents or information in this case shall be governed by the terms ofthe 7 Stipulation pS a~, i~r~_ ~;~, y~~. t 8 9 IT IS SO ORDERED. _, 10 11 DATED: ~ ~ c~ ~ ~ /~ ~~/ By: 12 nite tates the Central District of California 13 r 14 15 16 17 18 19 20 All future discover include the all followinil~~~~ ~~ Iarlguag~ on the cover g 21 22 page: " [Referred to Ma g Suzanne H. istrate Judge Segal]~~ 23 24 25 26 27 1 28 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 1 2 3 4 5 6 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: 213-680-2800 Facsimile: 213-614-7399 7 Attorneys for Defendant New York Life Insurance Company 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 NAZIMUDDIN HASHIM, 12 13 Plaintiff, vs. 14 NEW YORK LIFE INSURANCE COMPANY,AND DOES 1 THROUGH 15 10, 16 17 Defendants. Case No. 2:16-cv-07824-DMG-SS ( Honorable Dolly M. Gee) JOINT STIPULATION OF CONFIDENTIALITY COTE CHAF`~GES MADE BY THE COURT 18 19 2 0 21 22 23 4 2 25 2 6 27 28 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 1 TO THE HONORABLE DOLLY M. GEE AND HER COURT CLERK: 2 3 WHEREAS,Defendant New York Life Insurance Company("New York 4 Life" or "Defendant"), per the Court's Scheduling Order, is prepared to produce 5 confidential and proprietary claim manual documents to Nazimuddin Hashim 6 ( "Hashim")("Hashim" and "Defendant" referred to herein as "the Parties") in the 7 above-captioned action; 8 NOW THEREFORE,IT IS HEREBY STIPULATED AND AGREED as 9 f ollows: 10 11 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 13 " Confidential," shall be deemed "Confidential Information." 14 15 2 . 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. 18 19 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 21 22 23 > 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 4 2 this stipulation. 25 4 . "Qualified Person" as used herein means:(i) members, employees, 2 counsel, consultants, experts, co-counsel, or anyone else deemed by Defendant to be 6 27 28 HINSXAW b CULBERTSON 633 West 5th Stree[, 47M Floor Los Mgeles, CA 90071-2043 213-680-2800 1 JOINT STIPULATION OF CONFIDENTIALITY Case No. 2:16-cv-07824-DMG-SS 36266094v1 0991231 r- 1 necessary for the preparation ofthe case,(ii) Hashim, and,(iii) this Court and its 2 personnel. 3 5. The Confidential Information, or any portion thereof, may only be 4 disclosed to Qualified Persons and then only to the extent counsel in good faith 5 believes• that such disclosure i reasonably necessary to the prosecution or defense 6 ofthis litigation. 7 8 6. ~.~ C~ 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. 11 7 . 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 r 5~ 14 Confidential Information. C L S ~ ~~ ~~'~ ~ 15 16 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 18 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. 21 9 . 22 23 ocumen s i e wi the cis ofthe ual shall be filed under seal and under seal until further possible, 2 4 25 ,~~ 10. At the conclusion ofthis lawsuit(including appeals, if any), the 2 Confidential Information, or any portion thereof, in the possession of any Qualified 6 27 Person or any other person who has received such information pursuant to this 28 I MINSHAW d CULBERTSON 633 West 5th Street, 47M Floor Los Mgeles, CA 90071-2043 213-680-2800 2 JOINT STIPLTI,ATION OF CONFIDENTIALITY Case No. 2:16-cv-07824-DMG-SS 36266094v1 0991231 1 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 5 6 law for lawful purposes, or (ii) upon the written consent of the producing party. 1 1. 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. 11 he parties agree t at even if the Court 12 Proposed Order hereto, t e 13 of this StiPulation as a se arate a 14 will be snot sign and enter the nd by all ofthe terms and conditions forcea contract between t rties. ~'~S' IT IS SO STIPiTLATED. 15 16 ~ DATED: March 24, 2017 17 HINSHAW & CULBERTSON LLP By: /s/Martin E. Rosen 18 NIICHAEL S. NEVVMAN Attorneys for Defendant New York Life Insurance Company 19 20 21 22 23 24 DATED: March 24, 2016 By: DONAHUE & HORROW / s/Michael Horrow MICHAEL HORROW ELIZABETH FLEMNIING Attorneys for Plaintiff Nazimuddin Hashim 25 2 6 27 28 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

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