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LSH CO v. John Hancock Life Insurance Company (U.S.A.)

United States District Court, S.D. New York

January 10, 2020

LSH CO, and WELLS FARGO BANK, NATIONAL ASSOCIATION, as securities intermediary for LSH CO, Plaintiffs,
v.
JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.), and JOHN HANCOCK LIFE INSURANCE COMPANY OF NEW YORK, Defendants.

          Daniel P. Goldberg Avi Israeli Benjamin Heidlage HOLWELL SHUSTER & GOLDBERG LLP Attorneys for Plaintiffs

          Aar(B. Vickery John F. LaSalle III BOIES SCHILLER FLEXNER LLP Motty Shulman BOIES SCHILLER FLEXNER LLP Attorneys for Defendants

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          ALVIN K HELLERSTEIN, U.S.D.J.

         WHEREAS, Plaintiffs LSH CO and Wells Fargo Bank National Association, as securities intermediary for LSH CO (together, "Plaintiffs") and Defendants John Hancock Life Insurance Company of New York ("JHNY") and John Hancock Life Insurance Company (U.S.A.) ("JHUSA," and together with JHNY, "John Hancock," and, collectively with Plaintiffs, the "Parties" and individually a "Party") request that this Court issue a protective order pursuant to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and competitively sensitive information that they may need to disclose in connection with discovery in this action;

         WHEREAS, the Parties, through counsel, agree to the following terms; and

         WHEREAS, this Court finds good cause exists for issuance of an appropriately tailored confidentiality order governing the pretrial phase of this action, IT IS HEREBY ORDERED that any person subject to this Order - including without limitation the Parties to this action (including their respective corporate affiliates, parents, successors, and assigns), their partners, representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order- will adhere to the following terms, upon pain of contempt:

         1. With respect to "Discovery Material" (i.e., information of any kind produced or disclosed in the course of discovery in this action) that a person has designated as "Confidential" pursuant to this Order, no person subject to this Order may disclose such Confidential Discovery Material to anyone else except as this Order expressly permits:

         2. The Party or person producing or disclosing Discovery Material ("Producing Party"), or a Party in the case of information being produced by a third party ("Designating Party"), may designate as Confidential such material that it reasonably and in good faith believes consists of:

a. Proprietary business or competitively or commercially sensitive information, including but limited to information that, with respect to JHNY, JHUSA, their affiliates, parents, or their predecessors or successors, reveals their pricing practices and the underlying costs and components of their pricing practices, the calculations and thought process for the initial determination and subsequent readjustment of the cost of insurance rates for insurance policies they issue, the underlying methodology, data, assumptions (including but limited to lapse and mortality methodology, data and assumptions), and analysis for those initial determinations and subsequent readjustments;
b. previously non-disclosed financial information (including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports, and sale margins);
c. previously non-disclosed material relating to ownership or control of any non-public company;
d. previously non-disclosed business plans, product-development information, or marketing plans;
e. any information of a personal or intimate nature regarding any individual;
f. any other information the disclosure of which would be detrimental to the conduct of the ...

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