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Foskaris v. Experian Information Solutions, Inc.

United States District Court, D. Nevada

October 18, 2017

THOMAS FOSKARIS, Plaintiff,
v.
EXPERIAN INFORMATION SOLUTIONS, INC., Defendants.

          NAYLOR & BRASTER JENNIFER L. BRASTER CHERYL L. O'CONNOR ATTORNEYS FOR DEFENDANT EXPERIAN INFORMATION SOLUTIONS, INC.

          KNEPPER & CLARK LLC MILES N. CLARK ATTORNEYS FOR PLAINTIFF THOMAS FOSKARIS

          [PROPOSED] AMENDED STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED by and between Plaintiff Thomas Foskaris (“Plaintiff”)[1]and Defendant Experian Information Solutions, Inc. (“Experian”), through their respective attorneys of record:

         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 and supersedes the protective order entered on May 9, 2017 (Dkt. # 13):

         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 (a “Producing Party”) 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.”

         3. If a Producing Party believes in good faith that, despite the provisions of this Protective Order, there is a substantial risk of identifiable harm to the Producing Party if particular documents it designates as “Confidential” are disclosed to all other Parties or non-parties to this action, the Producing Party may designate those particular documents as “Confidential-Attorneys' Eyes Only.”

         4. 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, ” or “Confidential-Attorneys' Eyes Only” and shall file them with the clerk under seal; provided, however, that a copy of such filing having the confidential information deleted therefrom may be made part of the public record. Any party filing any document under seal must comply with the requirements of Local Rules.

         5. All documents, transcripts, or other materials subject to this Order, and all information derived therefrom (including, but not limited to, all testimony, deposition, or otherwise, that refers, reflects or otherwise discusses any information designated “ Confidential” or “Confidential-Attorneys' Eyes Only” hereunder), shall not be used, directly or indirectly, by any person, including Plaintiff and Experian 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 the provisions of this Order. As set forth in the preceding sentence, materials subject to this Order shall only be used for the preparation and trial of this action and shall not be used in any litigation other than the above-captioned action.

         6. Except with the prior written consent of the individual or entity designating a document or portions of a document as “Confidential, ” or pursuant to prior Order after notice, any document, transcript or pleading given “Confidential” treatment under this Order, and any information contained in, or derived from any such materials (including but not limited to, all deposition testimony that refers, reflects or otherwise discusses any information designated confidential hereunder) may not be disclosed other than in accordance with this Order and may not be disclosed to any person other than: (a) the Court and its officers; (b) parties to this litigation; (c) counsel for the parties, whether retained counsel or in-house counsel and employees of counsel assigned to assist such counsel in the preparation of this litigation; (d) fact witnesses subject to a proffer to the Court or a stipulation of the parties that such witnesses need to know such information; (e) present or former employees of the Producing Party in connection with their depositions in this action (provided that no former employees shall be shown documents prepared after the date of his or her departure; and (f) experts specifically retained as consultants or expert witnesses in connection with this litigation who have signed the “Declaration of Compliance” (Exhibit A).

         7. Except with the prior written consent of a Producing Party designating a document or portions of a document as “Confidential-Attorneys' Eyes Only”, or pursuant to prior Order after notice, any document, transcript or pleading given “Confidential-Attorneys' Eyes Only” treatment under this Order, and any information contained in, or derived from any such materials (including but not limited to, all deposition testimony that refers to, reflects or otherwise discusses any information designated “Confidential-Attorneys' Eyes Only” hereunder) may not be disclosed other than in accordance with this Order and may not be disclosed to any person other than: (a) a party's retained outside counsel of record in this action, as well as employees of said outside counsel to whom it is reasonably necessary to disclose the information for this litigation who have signed the “Declaration of Compliance” that is attached hereto as Exhibit A; (b) experts specifically retained as consultants or expert witnesses in connection with this litigation who have signed the “Declaration of Compliance” that is attached hereto as Exhibit A; (c) the Court and its personnel; (d) court reporters, their staffs, and professional vendors to whom disclosure is reasonably necessary for this litigation who have signed the “Declaration of Compliance” that is attached hereto as Exhibit A; and (e) the author of the document or the original source of the information.

         8. Documents produced pursuant to this Order shall not be made available to any person designated in Subparagraph 6(f) or 7(a), (b) & (d) unless he or she shall have first read this Order, agreed to be bound by its terms, and signed the attached Declaration of Compliance attached hereto as Exhibit A.

         9. All persons receiving any or all documents produced pursuant to this Order shall be advised of their confidential nature. All persons to whom confidential information and/or documents are disclosed are hereby enjoined from disclosing same to any person except as provided herein, and are further enjoined from using same except in the preparation for and trial of the above-captioned action between the named parties thereto. No person receiving or reviewing such confidential documents, information or transcript shall disseminate or disclose them to any person other than those ...


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