United States District Court, D. Montana, Missoula Division
BOZEMAN DEACONESS HEALTH SERVICES, INTERCITY RADIOLOGY P.C., and DEACONESS INTERCITY IMAGING LLC dba ADVANCED MEDICAL IMAGING, Plaintiffs,
FEDERAL INSURANCE COMPANY, ACE AMERICAN INSURANCE COMPANY, and CHUBB SERVICES CORPORATION, Defendants.
L. CHRISTENSEN, CHIEF JUDGE.
stipulation of the parties, and good cause shown, this Court
enters the following Protective Order, to govern the
discovery and protection of confidential proprietary
information, copyrighted and/or commercial information, which
may be and has been subject to discovery in this action:
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.
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 designed as
"Confidential" by a party. This Protective Order
shall also govern all information derived from such documents
and all copies, excerpts, or summaries of them.
Information may be deemed "Confidential" if it
contains trade secrets or other non-public, proprietary, or
competitively sensitive research, development, financial, or
commercial information, or information that, if publicly
disclosed, could be used to the competitive detriment of a
party or would violate the parties' respective
confidentiality and/or privacy policies and/or agreements,
including without limitation policies and/or agreements with
employees, customers, or third parties.
"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
parties shall not disclose information derived from such
Confidential information to any person except as provided in
this Protective Order.
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 in this lawsuit, and
(b) Any person retained by counsel representing the parties
to assist in the preparation of trial of this litigation,
including experts and paralegals;
(c) Any employee or representative of Bozeman Deaconess
Health Services, Intercity Radiology P.C., Deaconess
Intercity Imaging LLC dba Advanced Medical Imaging, Federal
Insurance Company, ACE American Insurance Company, and Chubb,
whose deposition is taken or is to be taken in this action
during the course of his or her testimony; and
(d) Deposition reporters.
person to whom disclosure of Confidential documents and
information is permitted by the parties pursuant to paragraph
5 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 ...