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Great Northern Insurance Co. v. TOTO U.S.A., Inc.

United States District Court, D. Colorado

November 10, 2015

GREAT NORTHERN INSURANCE COMPANY, an Indiana corporation, Plaintiff,
v.
TOTO U.S.A., INC., a Delaware corporation, Defendant.

STIPULATED PROTECTIVE ORDER

Judge R. Brooke Jackson Judge

This matter comes before the Court on Plaintiff Great Northern Insurance Company and Defendant Toto, U.S.A., Inc.’s (together the “parties”) Joint Motion for Entry of a Protective Order (“Motion”). The Court has reviewed the Motion. The Motion is meritorious and acceptable. Therefore, IT IS ORDERED:

1) This Stipulated Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.

2) As used in this Stipulated Protective Order, “document” is defined as provided in Fed.R.Civ.P. 34(a). A draft or non-identical copy is a separate document within the meaning of this term.

3) Information designated “CONFIDENTIAL” shall be information that is confidential and entitled to protection under Fed.R.Civ.P. 26(c)(1), or that contains (a) proprietary information of the Parties; or (b) information containing company trade secrets. {00155273.1 }

4) Confidential documents, materials, and/or information (collectively “ Confidential Information”) shall be used solely for the purpose of this action, and shall not, without the consent of the party producing it or further Order of the Court, be used, transferred, disclosed or communicated in any way, except that such information may be disclosed to:

(a) attorneys, whose law firms have entered an appearance in this case;
(b) persons regularly employed by the law firms which have entered an appearance in this case whose assistance is required by those attorneys in the preparation for trial, at trial, or at other proceedings in this case;
(c) the parties, including designated representatives for Defendant;
(d) expert witnesses and consultants retained in connection with this proceeding, to the extent such disclosure is necessary for preparation, trial or other proceedings in this case;
(e) the Court and its employees (“Court Personnel”);
(f) stenographic reporters who are engaged in proceedings necessarily incident to the conduct of this action;
(g) deponents, witnesses, or potential witnesses;
(h) any third party neutral chosen by the parties for the purposes of alternative ...

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