STIPULATION TO INCLUDE NAQVI INJURY LAW INTO THE STIPULATED CONFIDENTIALITY AND PROTECTIVE ORDER (ECF NO. 39) FOR THE DISCLOSURE OF DOCUMENTS PURSUANT TO F.R.C.P. 45 SUBPOENA

CARL W. HOFFMAN, Magistrate Judge.

Plaintiffs/Counter-defendants ALLSTATE INSURANCE COMPANY, ALLSTATE PROPERTY & CASUALTY INSURANCE COMPANY, ALLSTATE INDEMNITY COMPANY, and ALLSTATE FIRE & CASUALTY COMPANY (collectively referred to as the "Plaintiffs"), and NAQVI INJURY LAW (non-party herein after referred to as "NIL") hereby stipulate and agree as follows:

1. Plaintiffs served NIL with a subpoena pursuant to F.R.C.P. 45 for the production of documents regarding communications and payments made by and between Law Firm and the Defendants during NIL's representation of certain clients in personal injury claims for which Plaintiffs paid on settlement on behalf of Plaintiffs' insureds.

2. NIL provided a written objection to the Rule 45 subpoena.

3. NIL is aware that Plaintiffs have subpoenaed several law firms seeking the same type of information pursuant to Rule 45 in this case, as well as a companion sister-lawsuit Allstate v. Belsky, et. al. Case No. 2:15-cv-00065-MMD-CWH ("Belsky").

4. NIL understands that this Court presides over both the instant matter as well as the Belsky matter, and that this Court has ruled consistently in both these cases and ordered other law firms to produce the same type of documents request of NIL.

5. A stipulated confidentiality and protective order in this case entered between Plaintiffs and Defendants for the disclosure of confidential, sensitive or other protected information was approved by this Court on May 20, 2016. (ECF No. 39).

6. NIL was not a party to the stipulated confidentiality and protective order. (ECF No. 39).

7. In ordering compliance with Plaintiffs' subpoenas to other law firms, this Court also ordered that the confidentiality and protective order (ECF No. 39) be applied to those law firms.

8. In accordance with this Court's prior rulings both in this action and in the Belsky matter, the parties hereby stipulate and agree that the protections and scope articulated in the Stipulated Confidentiality and Protective Order approved by this Court on May 20, 2016. (ECF No. 39) be extended in their entirety to cover NIL in its compliance with Plaintiffs' subpoena.

9. NIL will produce all documents responsive to the subpoena within ten (10) days of approval and entry of this Order by the Court.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.