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Alvarez v. Bank of America, N.A.

United States District Court, D. Nevada

January 9, 2020

JOSE ALVAREZ, Plaintiff,
v.
BANK OF AMERICA, N.A.; TRANSUNION LLC; EXPERIAN INFORMATION SOLUTIONS, INC.; and EQUIFAX INFORMATION SERVICES, LLC, Defendants.

          Jennifer L. Braster Nevada Bar No. 9982 Andrew J. Sharples Nevada Bar No. 12866 NAYLOR & BRASTER, Katherine A. Neben Nevada Bar No. 14590 JONES DAY Attorneys for Defendant Experian Information Solutions, Inc.

          Darren T. Brenner (NBN 8386) Rex Garner (NBN 9401) AKERMAN LLP Attorneys for Defendant Bank of America, N.A.

          Bradley T. Austin (NBN 13064) SNELL & WILMER LLP Attorneys for Defendant Equifax Information Services, LLC

          Jennifer R. Bergh (NBN 14480) QUILLING SELANDER LOWNDS WINSLETT & MOSER Trevor Waite (NBN 13779) ALVERSON TAYLOR & SANDERS Attorneys for Defendant TransUnion, LLC

          Cam-Tu Dang (NBN 13093) PETERS AND ASSOCIATES, LLP Attorneys for Plaintiff Jose Alvarez

          JOINT STIPULATED PROTECTIVE ORDER

         IT IS HEREBY STIPULATED by and between Plaintiff Jose Alvarez, Defendant TransUnion LLC (“TransUnion”), Defendant Bank of America, N.A.; (“Bank of America”), Defendant Experian Information Solutions, Inc. (“Experian”), and Defendant Equifax Information Services, LLC (“Equifax”), through their respective attorneys 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. 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 Civil Local Rule 10-5.

         4. All documents, transcripts, or other materials subject to this Order, and all information derived therefrom (including, but not limited to, all testimony given in a deposition, declaration or otherwise, that refers, reflects or otherwise discusses any information designated “Confidential” shall not be used, directly or indirectly, by any person, including Bank of America, TransUnion, and Equifax, 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 to, 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 outside 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.

         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 ...


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