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Langford v. American National Insurance Service Co.

United States District Court, D. Montana, Billings Division

April 25, 2019

ALICIA LANGFORD, Plaintiff,
v.
AMERICAN NATIONAL INSURANCE SERVICE COMPANY Defendant.

          PROTECTIVE ORDER

          TIMOTHY J. CAVAN UNITED STATES MAGISTRATE JUDGE

         Upon motion of Defendant, and good cause shown, this Court enters the following Protective Order to govern the discovery and protection of confidential proprietary information, trade secret, and/or commercial information, the disclosure of which would be harmful to American National's business interests and would allow American National's competitors to unfairly gain competitive advantage over American National. The documents protected under the Protective Order are limited to American National's training manuals and training materials, which American National reasonably believes constitute confidential, trade secret information and which are identified as Bates Nos. American National 000512-001051.

         1. This Protective Order governs the access to, use, and distribution of information designated as “Confidential” in this litigation. For purposes of this Protective Order, “information” or “materials” includes documents, things, pleadings, discovery responses, deposition testimony, and all other discovery materials. American National has specifically identified Bates No. American National 000512-001051 as confidential, trade secret materials. The disclosure of these proprietary materials would be harmful to American National's business interests.

         2. This Protective Order shall also govern all discovery materials and/or papers filed with the Court in this case which include or make reference to any information designated as “Confidential” by a party. This Protective Order shall also govern all information derived from such documents, including excerpts or summaries of the “Confidential” documents.

         3. All “Confidential” information shall be treated as confidential during and throughout the pendency of this action. Confidential information shall be used by the non-producing party solely for the purposes of this litigation and not for any other purpose. Control and distribution shall be the responsibility of the attorneys of record.

         4. The parties shall not disclose information derived from such Confidential information to any person except as provided in this Protective Order. Confidential materials and information derived from them may be inspected and disclosed by the parties only to the following persons and only for the purposes of conducting this litigation:

(a) The parties, their counsel, and counsel's employees;
(b) Any person retained by counsel representing the parties to assist in the preparation of trial of this litigation, including experts and paralegals;
(c) Employees or representatives of American National Property and Casualty Company and its affiliates;
(d) Deposition reporters;
(e) Consulting attorneys or staff employed by counsel of record; and
(f) Other persons as the parties jointly agree or as the Court may order upon motion by either party.

         Court personnel are not subject to this Protective Order while engaged in the performance of their official duties.

         5. Each person to whom disclosure of Confidential documents and information is permitted by the parties pursuant to paragraph 4 above shall be shown a copy of this Protective Order and shall execute an acknowledgment in writing that he or she has received a copy of this ...


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