United States District Court, D. Nevada
N. Payne, Esq. PAYNE LAW FIRM LLC, Matthew I. Knepper, Esq.
Miles N. Clark, Esq. KNEPPER & CLARK LLC, David H.
Krieger, Esq. Nevada Bar No. 9086 HAINES & KRIEGER, LLC
Attorneys for Plaintiff
D. Bundick, GREENBERG TRAURIG, LLP, Attorneys for Defendant
JPMorgan Chase Bank, N.A.
Jennifer L Braster, Esq, NAYLOR & BRASTER, Attorneys for
Defendant Experian Information Solutions, Inc.
Bradley T. Austin, Esq., SNELL & WILMER LLP, Attorneys
for Defendant Equifax Information Services LLC,
G. Revzin, Esq., LEWIS BRISBOIS BISGAARD & SMITH LLP,
Attorneys for Defendant Trans Union LLC
[PROPOSED] STIPULATED PROTECTIVE ORDER
HEREBY STIPULATED by and between Plaintiff Roshonda Mayfield
and Defendants JPMorgan Chase Bank, N.A.
(“Chase”); Equifax Information Services, LLC
(“Equifax”), Experian Information Solutions, Inc.
(“Experian”), and Trans Union LLC (“Trans
Union”) (collectively, “the Parties”)
through their respective attorneys of record as follows:
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
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. 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, ” 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.
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 person, including Plaintiff,
Chase, Equifax, Experian, and TransUnion, 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.
5. 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
6. Documents produced pursuant to this Order shall not be
made available to any person designated in Subparagraph 5(f)
unless he or she shall have first read this Order, agreed to
be bound by its terms, and ...