Tolliver-McGregor v. Blue Cross and Blue Shield of Montana, Inc.

Filing 29

AGREED PROTECTIVE ORDER Signed by Judge Sam E Haddon on 3/3/2017. (Attachments: # 1 Exhibit A) (ELL)

EXHIBIT A
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MONTANA
BUTTE DIVISION

WENDY TOLLIVER-MCGREGOR,
Case No. 2:16-cv-00058

Plaintiff,
v.

AGREEMENT TO BE BOUND
BY PROTECTIVE ORDER

HEALTH CARE SERVICE
CORPORATION, an Illinois Mutual
Legal Reserve Company d/b/a BLUE
CROSS AND BLUE SHIELD OF
MONTANA,
Defendant.

1.

I am familiar with and agree to be bound by the terms of the Agreed

Protective Order in Case No. 2: 16-cv-00058, Tolliver-McGregor v. Health Care
Service Corporation, pending in the United States District Court for the District of
Montana.
2.

I will only make such copies of or notes concerning documents

designated "Confidential" as are necessary to enable me to render the assistance
required in connection with this litigation, and, all such notes and copies shall be
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preserved in a separate file maintained as "Confidential" and marked for
disposal or destruction upon completion of this litigation. Upon the final
determination of this action, I shall promptly destroy all "Confidential"
materials provided to me as well as any notes or derivations thereof.
3.

I will not intentionally reveal the contents of "Confidential" material

to any unauthorized person. I will not intentionally use "Confidential" material
for any purpose other than the prosecution or defense of claims in this action.
4.

I consent to the jurisdiction of the United States District Court for the

District of Montana for the purpose of enforcing the terms of the Protective Order.

DATED this

BY:

(Signature)

(Printed Name)

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