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Farmer v. Experian Information Solutions, Inc.

United States District Court, D. Nevada

September 21, 2017

TIMOTHY FARMER, Plaintiff,
v.
EXPERIAN INFORMATION SOLUTIONS, INC., EQUIFAX INFORMATION SERVICES, LLC, TRANS UNION LLC, ALLY FINANCIAL, CHASE MTG., FIRST TENNESSEE BANK, WELLS FARGO, WELLS FARGO BANK NA, AND WELLS FARGO FINANCIAL CARDS, Defendants.

          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.

          Gregg 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.

          Jason Revzin, Esq. LEWIS BRISBOIS BISGAARD & SMITH Counsel for Defendant Trans Union LLC.

          Kent F. Larsen, Esq. SMITH LARSEN & WIXOM Counsel for Defendant JP Morgan Chase Bnak, N.A., improperly sued as Chase Mtg.

          Kelly 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.

          Rex D. Garner, Esq. AKERMAN LLP Counsel for Defendant First Tennessee Bank.

          STIPULATED PROTECTIVE ORDER

         IT IS 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 follows:[1]

         WHEREAS, 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.

         THEREFORE, an Order of this Court protecting such confidential information shall be and hereby is made by this Court on the following terms:

         1. This 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.

         2. Any 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 Information”).

         3. To 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 ...


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