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Brown v. Credit One Bank, N.A.

United States District Court, D. Nevada

September 12, 2017

JEWELL BATES BROWN, an individual, Plaintiff,
v.
CREDIT ONE BANK, N.A., Defendant.

          Patrick J. Reilly, Esq. Susan M. Schwartz, Esq. Holland & Hart LLP Tuan V. Uong, Esq. Reed Smith, LLP Admitted Pro Hac Vice Attorneys for Respondent Credit One Bank, N.A.

          Mark Ankcorn, Esq. Admitted Pro Hac Vice Ann Marie Hansen, Esq. Ankcorn Law Firm, PC Michael Kind, Esq. Kazerouni Law Group, APC Attorneys for Claimant Jewell Bates Brown

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

         STIPULATED PROTECTIVE ORDER

          Plaintiff Jewel Brown-Bates (“Plaintiff”) and Defendant Credit One Bank, N.A. (“Defendant, ” together with Plaintiff, the “Parties”), through their respective attorneys of record, agree and stipulate as follows:

1. Terms: The terms defined in this Paragraph shall have the meanings provided. Defined terms may be used in the singular or plural.
1.1 “Producing Party” means the party, or person other than a party, being asked to produce documents or information considered by that party or person to be Confidential Information, or a party asserting a confidentiality interest in information produced by others.
1.2 “Receiving Party” means that party receiving or requesting production of Confidential Information.
1.3 “Confidential Information” means information, whether or not embodied in any physical medium, including all originals and copies of any document and/or information, used by the Producing Party in or pertaining to its business, or information pertaining to third-party privacy interests, which information the Producing Party believes in good faith to be protected from disclosure under applicable law as (i) private information, (ii) trade secrets, (iii) non-public competitive financial or business planning information that the Producing Party is prohibited by law or contract from revealing to third parties except in confidence, or has undertaken by contract with others to maintain its confidence. Nothing herein is intended to confer confidential or protected status on information that is not otherwise protected under Nevada or federal law or which has been publicly disseminated.
1.4 “Litigation Documents” means all pleadings, motions, affidavits, declarations, and related papers, all documents produced or exchanged in the course of this matter or any settlement negotiations, all written discovery responses and all transcripts and testimony given at any proceedings or hearings of any kind.
1.5 “Action” specifically refers to the proceedings or settlement in the above-captioned action.
1.6 “Termination” means the settlement of this Action, dismissal of this Action, entry of final judgment and expiration of all periods to appeal or seek arbitral or judicial review of this Action.
1.7 “Order” refers to this Stipulated Protective Order and Confidentiality Agreement and [Proposed] Order.

         2. Use Of Confidential Information.

         2.1 All documents and information designated in good faith by a party to the Action as Confidential Information shall be used solely for the purposes of this Action and shall not be used for any other purpose, including, without limitation, any media communications, public relations matter, business or commercial purpose, product development, intellectual property development, or in any other legal proceeding, action or matter and shall not, directly or indirectly, in whole or in part, be revealed or disclosed, or made available for inspection or copying to persons other than “qualified persons” as defined in paragraphs 2.2. Notwithstanding the above, a party to the litigation may use their own Confidential Information as they see fit unless doing so would disclose another party's Confidential Information and that other party does not consent in writing to that use.

         2.2 “Qualified Person” for ...


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