United States District Court, D. Nevada
HIEP D. LE, Plaintiff,
BANK OF AMERICA, NATIONAL ASSOCIATION; EQUIFAX INFORMATION SERVICES, LLC, Defendants.
Bradley T Austin Snell & Wilmer LLP Attorneys for
Defendant Equifax Information Services LLC.
H. Krieger Haines & Krieger, LLC Attorneys for Plaintiff.
STIPULATED PROTECTIVE ORDER
hereby stipulated by and between Plaintiff, Hiep Le
(“Plaintiff”), and Defendant, Equifax Information
Services LLC (“Defendant”), through their
respective attorneys of record, as follows:
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.
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.
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.
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
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.
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.
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.
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 ...