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Le v. Bank of America, National Association

United States District Court, D. Nevada

March 3, 2017

HIEP D. LE, Plaintiff,
v.
BANK OF AMERICA, NATIONAL ASSOCIATION; EQUIFAX INFORMATION SERVICES, LLC, Defendants.

          Bradley T Austin Snell & Wilmer LLP Attorneys for Defendant Equifax Information Services LLC.

          David H. Krieger Haines & Krieger, LLC Attorneys for Plaintiff.

          STIPULATED PROTECTIVE ORDER

         It is hereby stipulated by and between Plaintiff, Hiep Le (“Plaintiff”), and Defendant, Equifax Information Services LLC (“Defendant”), through their respective attorneys of record, as follows:

         1. This Order shall govern the use, handling and disclosure of all documents, testimony or information produced or given in this action that are designated to be subject to this order in accordance with the terms hereof.

         2. Any party producing or filing documents or other materials in this action may designate such materials and the information contained therein subject to this order by typing or stamping on the front of the document, or on portion(s) of the document for which confidential treatment is desired, “CONFIDENTIAL” if the party has a reasonable and good faith belief the material contains a trade secret or other confidential research, development or commercial information, or personal or financial information of a consumer other than plaintiff.

         3. All materials designated as CONFIDENTIAL, and all information derived therefrom (including but not limited to all testimony, deposition or otherwise, that refers, reflects or otherwise discusses any such materials), shall not be used, directly or indirectly, by any person for any business, commercial or competitive purposes or for any purpose whatsoever other than solely for the preparation and trial of this action in accordance with this Order.

         4. Except with the prior written consent of the party asserting confidential treatment or pursuant to court order, any document or materials given confidential treatment under this order, and any information contained in, or derived from, any such materials may not be disclosed other than in accordance with this order and may not be disclosed to any person other than the court and:

a. Parties to this litigation;
b. Counsel for the respective parties to this litigation and clerks, paralegals, secretaries or other employees of counsel;
c. Witnesses expected to be deposed or to testify in court or by affidavit in this litigation;
d. Experts specially retained as consultants or expert witnesses in connection with this litigation.

         5. Documents produced pursuant to this order shall not be made available to any person designated in subparagraph 4(d) unless he or she shall have first read this order and agree to be bound by its terms.

         6. The parties and their attorneys shall take all necessary and proper steps to preserve the confidentiality of, and to protect the rights of the party asserting confidential treatment with respect to, any information designated by said party as CONFIDENTIAL in accordance with this order.

         7. If CONFIDENTIAL information submitted in accordance with this order is disclosed to any person other than in a manner authorized by this order, the party responsible for the disclosure must immediately upon learning of the disclosure bring all pertinent facts relating to such disclosure to the attention of the party asserting confidential treatment, make every effort to ...


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