Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Carcelen v. Citibank, N.A.

United States District Court, D. Nevada

December 17, 2019

ADRIANA CARCELEN, Plaintiff,
v.
CITIBANK, N.A., a national banking association; SYNCHRONY BANK, a foreign corporation; EQUIFAX INFORMATION SOLUTIONS, INC., a foreign limited-liability company; EXPERIAN INFORMATION SOLUTIONS, INC., a foreign corporation; and TRANS UNION LLC, a foreign limited-liability company; Defendants.

          Matthew Tsai, Esq. Nevada Bar No. 14290 Lewis Roca Rothgerber Christie LLP Attorneys for Defendant Synchrony Bank

          Kevin L. Hernandez NV Bar No. 12594 LAW OFFICE OF KEVIN L. HERNANDEZ Counsel for Plaintiff Adriana Carcelen

          JOINT MOTION AND ORDER FOR ENTRY OF CONFIDENTIALITY STIPULATION

         COME NOW Plaintiff Adriana Carcelen (“Plaintiff”) and Defendant Synchrony Bank (“Synchrony”, and together with Plaintiff, the “Parties”), by counsel, and jointly move under LR 7-1(c) for entry of the Protective Order of Confidentiality (“Order”), as follows:

         STATEMENT OF JOINT MOTION

         1. The Parties are exploring the possibility of early resolution, and have determined that the informal exchange of documents considered confidential would facilitate negotiations.

         2. The Order would permit the Parties to exchange documents considered confidential.

         3. The Order is entered into and binds Plaintiff and Synchrony only, and not any other party involved in this litigation.

         4. The Order does not preclude the Parties from entering into other similar confidentiality agreements involving other parties involved in this litigation.

         5. Counsel for Synchrony conferred with counsel for Plaintiff regarding this Order, and both Parties agree to be bound by the Order and jointly move the Court for its entry.

         6. This Joint Motion is filed in good faith and not for dilatory or other improper purpose.

         WHEREFORE, Plaintiff Adriana Carcelen and Defendant Synchrony Bank respectfully request that this Court enter the stipulated Protective Order of Confidentiality, attached hereto as Exhibit A.

         EXHIBIT A

         PROTECTIVE ORDER OF CONFIDENTIALITY

         This Protective Order of Confidentiality (“Order”) is made and agreed to by The Law Offices of Kevin L. Hernandez on behalf of Plaintiff Adriana Carcelen (“Carcelen”) and Lewis Roca Rothgerber Christie LLP (“LRRC”) on behalf of Synchrony Bank (“Synchrony”) (each a “Party” and collectively the “Parties”), on behalf of their respective clients in connection with the civil action captioned Adriana Carcelen v. Citibank, N.A., et al, No. 2:19-cv-01533-APG-VCF (the “Action”) currently pending in the United States District Court for the District of Nevada (the “Court”).

         PREAMBLE

         The discovery that may be sought and documents and information that may be exchanged by the parties in the Action may include identification and release of certain documents that are considered confidential and/or proprietary information (“Confidential Information”). Counsel for the parties to this action agree to execute this Order prior to production of any Confidential Information. Synchrony and Carcelen (the “Obligated Parties”) agree to be bound by the terms of the Order upon execution of this document.

         AGREEMENT

         1. Scope. All materials produced or adduced in the course of discovery, including informal exchange of documents, initial disclosures, responses to discovery requests, deposition testimony and exhibits, and information derived directly therefrom (hereinafter collectively “documents”), shall be subject to this Order concerning Confidential Information as defined below. This Order is subject to the Local Rules of the United States District Court for the District of Nevada and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. Confidential Information. As used in this Order, “Confidential Information” means information designated as “Confidential” or “Confidential - ATTORNEYS' EYES ONLY” by the producing Party that falls within one or more of the following categories: (a) business records including account notes, applications, call recordings and the like; (b) information prohibited from disclosure by statute; (c) information that reveals trade secrets or proprietary commercial information, including but not limited to business records such as account notes, applications, call recordings and the like; (d) manuals, policies, procedures, research, technical, commercial or financial information that the Party has maintained as confidential; (e) personal health or medical information protected by the Health Insurance Portability and Accountability Act; (f) personal identifying information such as Social Security ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.