United States District Court, D. Nevada
REBECCA A. WHITLOCK-ALLOUCHE, Plaintiff,
PLUSFOUR, INC; AMERASSIST A/R SOLUTIONS; EQUIFAX INFORMATION SERVICES, LLC; TRANS UNION, LLC, Defendants.
Michael Kind, Esq., Kazerouni Law Group, APC, David H.
Krieger, Esq., HAINES & KRIEGER, LLC., Attorneys for
Plaintiff REBECCA A. WHITLOCK-ALLOUCHE.
Raleigh C. Thompson, Esq., Ryan M. Lower, Esq., Morris Law
Group., Attorneys for Defendant PLUSFOUR, INC.
STIPULATED PROTECTIVE ORDER
REBECCA A. WHITLOCK-ALLOUCHE ("Plaintiff) and Defendant
PLUSFOUR, INC (collectively, the "Parties"),
and through their counsel of record, hereby stipulate 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."
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, " 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.
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 hereunder), shall not be used,
directly or indirectly, by any person, 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.
depositions or portions of depositions taken in this action
that contain confidential information may be designated as
"Confidential" and thereby obtain the protections
accorded other confidential information. The parties shall
have twenty-one (21) days from the date a deposition is
taken, or fourteen (14) days from the date a deposition
transcript is received, whichever date is greater, to serve a
notice to all parties designating portions as
"Confidential." Until such time, all deposition
testimony shall be treated as confidential information. To
the extent any designations are made on the record during the
deposition, the designating party need not serve a notice
re-designating those portions of the transcript as
confidential information. Any party may challenge any such
designation in accordance with Paragraph 14 of this Order.
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
Documents produced pursuant to this Order shall not be made
available to any person designated in Subparagraph 6(f)
unless he or she shall have first read this Order, agreed to
be bound by its terms, and signed the attached Declaration of
Third parties who are the subject of discovery requests,
subpoenas or depositions in this case may take advantage of
the provisions of this Protective Order by providing the
parties with written notice that they intend to comply with
and be bound by the terms of this Protective Order.
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 ...