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Woodmen of World Life Insurance Society v. Woodmen of World And/Or Assured Life Association

United States District Court, D. Nebraska

July 28, 2014

WOODMEN OF THE WORLD LIFE INSURANCE SOCIETY, A Nebraska Not for Profit Fraternal Benefit Society, Plaintiff/Counterclaim Defendant,
v.
WOODMEN OF THE WORLD AND/OR ASSURED LIFE ASSOCIATION, a Colorado Benefit Society Defendant/Counterclaim Plaintiff.

Patrick G. Vipond, Mark Novotny, Cathy S. Trent-Vilim, LAMSON, DUGAN and MURRAY, LLP, Omaha, NE, Attorneys for Plaintiff.

Pamela E. Olsen, Andre R. Barry, Cline Williams Wright, Johnson & Oldfather, L.L.P., Lincoln, NE, Frank D. O'Loughlin, Cindy C. Oliver, Joy Allen Woller, LEWIS ROCA ROTHGERBER LLP, Denver, CO, Attorneys for Woodmen of the World and/or Assured Life Association, a Colorado not for Profit Fraternal Benefit Society.

STIPULATED PROTECTIVE ORDER

LYLE E. STROM, District Judge.

WHEREAS, Plaintiff/Counterclaim Defendant, Woodmen of the World Life Insurance Society ("Plaintiff"), has filed this action against Defendant/Counterclaim Plaintiff, Woodmen of the World and/or Assured Life Association ("Defendant") (collectively, hereinafter "the Parties"); and Defendant has filed Counterclaims against Plaintiff; and

WHEREAS, certain documents to be produced in this action are claimed by the Parties to contain proprietary, sensitive material, and/or other confidential information of the Parties and other third parties, including but not limited to protected from disclosure by the Health Insurance Portability and Accountability Act ("HIPAA"), the Gramm Leach Bliley Act, and other state or federal laws; and

WHEREAS, the Parties desire to preserve the confidentiality of such information;

IT IS HEREBY ORDERED THAT:

1. As used in this Protective Order:

(a) "Attorneys" means counsel of record;
(b) "Attorneys Eyes Only" Information is information defined in paragraph 3 below and as marked or identified in paragraph 4 below.
(c) "Confidential Information" is information as defined in paragraph 2 below and as marked or identified in paragraph 4 below;
(d) "Documents" include all materials within the scope of Fed.R.Civ.P. 34;
(e) "Outside Independent Persons" means persons or firms retained by a party or its Attorneys to provide assistance as mock jurors or focus group members, to furnish technical or expert services, or to give testimony in this litigation;
(f) "Outside Vendors" means messenger, copy, coding, document management, document review, and other clerical or electronic document service vendors not employed by a party or its Attorneys; and
(g) "Protected Information" means information designated as either "Confidential Information" or "Attorneys Eyes Only Information" under the terms of this Stipulated Protective Order and when used in this Order refers to and encompasses both Confidential Information and Attorneys Eyes Only Information.
(h) "Written Assurance" means the document in the form attached as Exhibit "A" to this Protective Order.

2. The term "Confidential Information" as used in this Protective Order shall refer to those documents designated as "Confidential, " including but not limited to:

(a) "HIPAA Confidential Information." "HIPAA Confidential Information" shall include any document created or received by any health care provider, health plan, public health authority, employer, life insurer, school or university, or health care clearinghouse that relates to any physical or mental health condition of an individual, the provision of health care to an individual, or the payment for the provision of health care to an individual;
(b) Documents protected from disclosure by the Gramm Leach Bliley Act;
(c) Documents protected from disclosure by any other federal law;
(d) Documents protected from disclosure by any law of the state of party ...

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