United States District Court, D. Nevada
Matthew I. Knepper, Esq. Miles N. Clark, Esq. KNEPPER &
CLARK LLC David H. Krieger, Esq. HAINES & KRIEGER, LLC
Counsel for Plaintiff.
Bradley T. Austin, Esq. SNELL & WILMER LLP Counsel for
Defendant Equifax Information Services, LLC.
A. Hubley, Esq. BROOKS HUBLEY LLP Counsel for Defendant Ally
Financial Jennifer Braster.
Jennifer L. Braster, Esq. Andrew J. Sharples, Esq. NAYLOR
& BRASTER Edward San Chang, Esq. (Pro Hac Vice) JONES DAY
Counsel for Defendant Experian Information Solutions, Inc.
Revzin, Esq. LEWIS BRISBOIS BISGAARD & SMITH Counsel for
Defendant Trans Union LLC.
F. Larsen, Esq. SMITH LARSEN & WIXOM Counsel for
Defendant JP Morgan Chase Bnak, N.A., improperly sued as
H. Dove, Esq. Tayna N. Lewis, Esq. SNELL & WILMER L.L.P.
Counsel for Defendants Wells Fargo, Wells Fargo Bank N.A.,
and Wells Fargo Financial Card.
Garner, Esq. AKERMAN LLP Counsel for Defendant First
STIPULATED PROTECTIVE ORDER
HEREBY STIPULATED by and between Plaintiff TIMOTHY FARMER
(“Plaintiff”), and Defendants EXPERIAN
INFORMATION SOLUTIONS, INC.; EQUIFAX INFORMATION SERVICES,
LLC; TRANS UNION LLC; ALLY FINANCIAL; WELLS FARGO; WELLS
FARGO BANK N.A.; WELLS FARGO FINANCIAL CARDS and FIRST
TENNESSEE BANK, (collectively, the “Parties”), by
and through their counsel of record, as
documents and information have been and may be sought,
produced or exhibited by and among the parties to this action
relating to trade secrets, confidential research,
development, technology or other proprietary information
belonging to the defendants and/or personal income, credit
and other confidential information of Plaintiff.
an Order of this Court protecting such confidential
information shall be and hereby is made by this Court on the
Order shall govern the use, handling and disclosure of all
documents, testimony or information produced or given in this
action which are designated to be subject to this Order in
accordance with the terms hereof.
party or non-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 the
portion(s) of the document for which confidential treatment
is designated, “Confidential” or
“Confidential - Attorney's Eyes Only”
(hereinafter collectively referred to as “Confidential
the extent any motions, briefs, pleadings, deposition
transcripts, or other papers to be filed with the Court
incorporate documents or information subject to this Order,
the party filing such papers shall designate such materials,
or portions thereof, as “Confidential Information,
” and shall file them with the clerk under seal;
provided, however, that a copy of such filing having the
confidential information deleted therefrom may ...