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Valentine v. Equifax Information Services, LLC

United States District Court, D. Nevada

February 6, 2017

Monika A. Valentine and William R. Valentine, Plaintiffs,
v.
Equifax Information Services, LLC and Wells Fargo Home Mortgage, Defendants.

          Michael Kind, Esq., David H. Krieger, Esq., HAINES & KRIEGER, LLC Attorneys for Plaintiffs

          JEFFREY WILLIS, TANYA N. PETERS Attorneys for Defendant

          STIPULATION FOR PROTECTIVE ORDER

         IT APPEARING TO THIS COURT that Plaintiffs Monika A. Valentine and William R. Valentine (“Plaintiff”) and Defendant Wells Fargo Home Mortgage (“Defendants”), sometimes collectively referred to herein as the “Parties, ” have agreed, by and through their counsel of record, to the following terms and procedures that will govern disclosures and use by the Parties of documents, testimony, and information that is produced or given by any person during the course of discovery in the above-captioned action (the “Action”), and designated “Confidential.” The Parties have met in good faith and Defendants have agreed to stipulate to this Protective Order. Therefore, the Court finding that a Protective Order is warranted and for good cause shown, it is hereby

         ORDERED that the following terms and conditions shall govern discovery in this Action:

         1. The term “Information” as used herein shall include any document, deposition testimony, electronic data, interrogatory response, response to request for admission, or other information disclosed or produced by or on behalf of a party (or any of its attorneys or other agents), or by or on behalf of a non-party (or any of its attorneys or other agents), and all information derived therefrom.

         2. Information may be designated by a party responding to a discovery inquiry (the “Producing Party”) as “Confidential” within the meaning of this Stipulation for Protective Order. The Producing Party shall designate Information “Confidential” only when the Producing Party has a reasonable, good faith belief that the Information so designated is confidential within the meaning of Fed.R.Civ.P. 26(c) and further defined as follows:

a. “Confidential” Information includes confidential commercial or non-public information that qualifies for protection under Fed.R.Civ.P. 26(c), the dissemination of which is generally protected by the Producing Party in the normal course of business; and Any Information not designated as “Confidential” in accordance with the procedures set forth herein shall not be covered by this Stipulation for Protective Order.

         3. “Confidential” Information, except with the prior consent of the Producing Party (which shall not be unreasonably withheld) or upon prior order of this Court, shall not be disclosed by any party to any person other than the following:

a. the Court, Court personnel, jurors, mediators, and arbitrators;
b. outside counsel for the Parties in this litigation and their secretaries, legal assistants, or other support personnel as reasonably necessary to assist outside counsel in this Action (collectively “Outside Litigation Counsel”);
c. the Parties as well as those officers, directors, in-house attorneys, or employees of the Parties who are actively involved in the Action or who are otherwise necessary to aid counsel in the Action;
d. court reporters and videographers who are retained to transcribe or videotape testimony in this Action;
e. outside experts, consultants, and/or litigation support vendors who are not employees of any party and who are expressly retained to assist counsel of record for either of the Parties in connection with this Action, including, but not limited to, independent auditors, accountants, statisticians, economists and other experts, and the employees of such persons (collectively “Outside Litigation Assistants”);
f. any other person to whom the Parties in writing agree, provided that any such person must sign an Acknowledgment in the ...

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