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Sielaw v. Ally Financial

United States District Court, D. Nevada

January 31, 2018

Virginia Sielaw, Plaintiff,
v.
Ally Financial f/k/a GMAC Automotive Bank, Barclays Bank Delaware, Equifax Information Services LLC and Trans Union LLC, Defendants.

          Jason G. Revzin, Esq. Attorneys for Defendant Trans Union LLC

          Michael Kind, Esq. (SBN: 13903) KAZEROUNI LAW GROUP, APC

          David H. Krieger, Esq. (SBN: 9086) HAINES & KRIEGER, LLC Attorneys for Plaintiff Virginia Sielaw

          [PROPOSED] STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED by and between Plaintiff Virginia Sielaw (“Plaintiff”) and Defendant Trans Union LLC (“Defendant”) (collectively as “the Parties”), by and through their counsel of record, as follows:

         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.”

         3. See order issued concurrently herewith.

         4. 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 hereunder), shall not be used, directly or indirectly, by any Party, 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.

         5. All 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.

         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.

         7. 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 Compliance.

         8. 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 ...


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