MOTORISTS MUTUAL INSURANCE CO., INSURER FOR DEFENDANT QC FABRICATON, INC.'S MOTION FOR PROTECTIVE ORDER AND AFFIDAVIT OF RANDALL MCKINNEY.

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          te 1g,
ay ‘4
IN THE COURT OF COMMON PLEAS ”P
SUMMIT COUNTY, OHIO 0 My o
LEBEN,
oi OO) I

BEVERLY NOVAK, et al. CASE NO. CV 2008-09-6709 ~”

133

Plaintiffs, JUDGE JUDITH L. HUNTER

v.

INSURANCE COMPANY FOR
PROTECTIVE ORDER AND
AFFIDAVIT OF RANDALL
McKINNEY

ROBERT STUDEBAKER, et al.

)
)
)
)
)
) MOTION OF MOTORISTS MUTUAL
)
)
Defendants. )
)
)

Now comes Motorists Mutual Insurance Company, which is the insurer for Defendant
QC Fabrication, Inc., and, pursuant to Ohio Civil Rule 26(C), hereby moves this Court for a
Protective Order with respect to a portion of its claims file which has been requested by the
Plaintiffs pursuant to a subpoena. (See Exhibit A attached hereto). The reasons for this Motion
for Protective Order are numerous, including but not limited to the following: (1) many of the
documents requested are irrelevant; (2) some of the claims file relates to claims for coverage
asserted by other persons or entities, which does not involve QC Fabrication, Inc.; (3) some of
th…