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Driskell v. Towne Mortgage Co.

United States District Court, D. Nevada

May 23, 2018

Frankie M. Driskell, Plaintiff,
v.
Towne Mortgage Company, LenderLive Network, LLC, Experian Information Solutions, Inc., Equifax Information Services, LLC and Trans Union LLC, Defendants.

          KAZEROUNI LAW GROUP, APC Michael Kind, Esq. Attorneys for Plaintiff

          MORRIS LAW GROUP Steve L. Morris, Esq., Raleigh C. Thompson, Esq. Attorneys for Defendant Towne Mortgage Company

          NAYLOR & BRASTER Andrew J. Sharples, Jennifer L. Braster, Esq., Andrew J. Sharples, Esq. Attorneys for Defendant Experian Information Solutions, Inc.

          BALLARD SPAHR LLP Joel Edward Tasca, Esq., Stacy H. Rubin, Esq. Attorneys for Defendant LenderLive Network, LLC

          [PROPOSED] STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED by and between Plaintiff Frankie M. Driskell ("Plaintiff) and Defendants Towne Mortgage Company, LenderLive Network, LLC, and Experian Information Solutions, Inc., (“Defendants”) (Plaintiff and Defendants collectively referred to herein as “the Parties” and severally a “Party”), 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 any of the defendants and/or personal income, credit and other confidential information of Plaintiff ("Confidential Material").

         THEREFORE, an Order of this Court protecting such Confidential Material 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 as Confidential Material in accordance with 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 as Confidential Material 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 burden of proof to establish that the information or document is entitled to such protection is on the Party that designated the information or document as Confidential, as detailed in Paragraph 14 of this Order.
3. To the extent any motions, briefs, pleadings, deposition transcripts, or other papers to be filed with the Court incorporate Confidential Material, 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 Material redacted 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 designated as Confidential, and all information derived therefrom (including, but not limited to, all testimony, deposition, or otherwise, that refers, reflects or otherwise discusses any information designated as Confidential Material), shall not be used, directly or indirectly, by any Party, for 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 Material 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 Material in accordance with this Order. 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 Material. 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) any fact witnesses who 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); (f) any individual who had received the Confidential Material at any time in the past 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 (g) unless he or she shall have first read this Order, agreed to be bound by its terms, and ...

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