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Medical Mutual Insurance Company of North Carolina v. Indian Harbor Insurance Company

United States District Court, E.D. North Carolina, Western Division

March 13, 2017

MEDICAL MUTUAL INSURANCE COMPANY OF NORTH CAROLINA, Plaintiff,
v.
INDIAN HARBOR INSURANCE COMPANY, Defendant.

          ROBINSON BRADSHAW & HINSON Attorney for Plaintiff Medical Mutual Insurance Company of North Carolina

          GARY P. SELIGMAN Attorney for Defendant Indian Harbor Insurance Company (Special Appearance per L. Civ. R. 83.1(e))

          CONSENT PROTECTIVE ORDER

          Robert T. Numbers, II United States Magistrate Judge

         Plaintiff Medical Mutual Insurance Company of North Carolina (“Medical Mutual”) and Defendant Indian Harbor Insurance Company (“Indian Harbor”) (each individually a “Party” and collectively “the Parties”), by and through their respective counsel, have jointly stipulated to the terms of the following Protective Order:

         SCOPE

         1. This Protective Order applies to all disclosures, affidavits and declarations and exhibits thereto, deposition testimony and exhibits, discovery responses, documents, electronically stored information, tangible objects, information, and other things produced, provided or disclosed in the course of this action by any Party (the “Producing Party”) to any Party (the “Receiving Party”) which may be subject to restrictions on disclosure under this Protective Order, and information derived directly therefrom (all such information hereinafter referred to as “Material”). This Protective Order also applies to all information, documents, and things derived from the Material, including, without limitation, copies, summaries, or abstracts. This Protective Order is subject to the Local Civil Rules and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. This Protective Order has no effect upon, and does not apply to, a Party's use of its own confidential information for any purpose.

         3. All Material designated in the course of the above-captioned litigation (“Litigation”) as “Confidential, ” as that term is defined in Paragraph 6, is to be used only for the purpose of preparation and trial of this Litigation, and any appeal therefrom, and shall not be used, directly or indirectly, for any other purpose whatsoever, and shall not be disclosed to any person, corporation, partnership, joint venture, association, joint stock company, limited liability company, trust, unincorporated organization, government body or other entity (collectively “Person”) except in accordance with the terms hereof.

         4. Notwithstanding anything to the contrary, nothing in this Protective Order prevents the disclosure of any confidential information to lawyers, accountants, auditors, insurance brokers, insurers/reinsurers (if any), together with such insurers/reinsurers' third-party service providers, actuaries or intermediaries or regulators (collectively “Recipients”), provided the disclosure is reasonably necessary to effectuate the terms of this Protective Order or is required for tax, financial reporting, or governmental compliance purposes, or to transact the business of insurance. Prior to disclosure, the Recipients are to be informed of the confidential nature of the information and agree to keep such information confidential.

         5. The attorney-client privilege, work product protection, or any other applicable privilege or doctrine is not waived by disclosure of Material in the Litigation, and any such disclosure shall also not constitute a waiver in any other federal or state proceeding.

         DEFINITIONS

         6. “Confidential” means Material that the Producing Party has treated as confidential in the ordinary course of business, which must not have been disclosed publicly, and with respect to which the Producing Party has made a good faith determination that the Material contains information protected from disclosure by statute or that should be protected from disclosure as confidential business or personal information, medical or psychiatric information, trade secrets, personnel records, or such other sensitive commercial information that is not publicly available. Such information may be disclosed to only Qualified Persons as defined in Paragraph 7 below.

         7. With respect to Confidential Material, “Qualified Persons” means:

(a) Judges and court personnel of this Court; judges and personnel of any other court where disclosure is necessary in connection with a motion or other matter relating to the Litigation (including any appeal); and certified court reporters acting as such (along with videographers);
(b) Counsel of record for the Parties in the Litigation and employees in those law firms whose functions require access to Materials ...

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