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Patterson v. Equifax Information Services, LLC

United States District Court, E.D. North Carolina

May 14, 2018


          Asa C. Edwards, Edward H. Maginnis, Asa C. Edwards IV, Karl S. Gwaltney MAGINNIS LAW PLLC Counsel for Plaintiff

          Robert de Rossett YOUNG MOORE & HENDERSON, P.A. AND Paul L. Myers Quilling, Selander, Lownds, Winslett & Moser, P.C. Counsel for Trans Union

          Bradley J. Lingo, Chelsea J. Corey, Theodore Roethke KING & SPALDING LLP Counsel for Equifax Information Services, LLC

          Ashley K. Brathwaite ELLIS & WINTERS LLP Counsel for Defendant Experian Information Solutions, Inc.


          Robert T. Numbers, II United States Magistrate Judge.

         This Consent Protective Order is issued to facilitate the exchange of documents and information. Unless modified pursuant to the terms contained in this Order, this Order shall remain in effect through the conclusion of this litigation.

         1. Sylvia Patterson ("Plaintiff) filed this lawsuit (the "Litigation") against Defendants Synchrony Bank[1], Equifax Information Services, LLC, Trans Union LLC, and Experian Information Solutions, Inc. (collectively referred to as "Defendants"), alleging that Defendants are liable to Plaintiff for, inter alia, damages resulting from alleged violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681, et seq. ("FCRA"). In connection with the Litigation, Plaintiff has sought discovery or testimony regarding certain of Defendants' confidential and proprietary trade secrets and other business information. Plaintiff and Defendants may be collectively referred to herein as "the Parties" or individually as a "Party." As a means of avoiding continued dispute with respect to any Parties' requests for confidential information, the Parties have agreed to produce certain confidential information pursuant to the terms of this Order.

         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." Documents or portions of a document marked as "Confidential" are to be used only for the litigation of this case; all other uses are prohibited.

         3. The Parties shall have the right to designate as "Confidential" any part or the whole of any answers to discovery, answers to interrogatories, answers to requests for admission, deposition transcripts, responses to production requests, documents, expert reports, disclosures, exhibits, trial or deposition testimony or other information that the Parties deem to be confidential. Any document, discovery, testimony, or other information that the Parties have designated as "Confidential" shall constitute confidential information under this Order, both in form and substance.

         4. Deposition testimony can be designated by the Parties as "Confidential." Such designation will be made on the record if possible, but the Parties can designate portions of such testimony as "Confidential" by providing written notice of such designation to the opposing Parties within thirty (30) days of receipt of the transcribed testimony by counsel. Until thirty (30) days after receipt of the transcribed testimony, such testimony shall be treated by the Parties as "Confidential." 5. Information designated for confidential treatment provided by any of the Parties shall be used strictly in accordance with the terms in this Order. At no time shall such information be disclosed to or used by any person, corporation, or entity in competition with or against any of the Parties.

         6. The Parties, their attorneys, or anyone else acting on their behalf shall take such precautions with "Confidential" information as are necessary to strictly maintain its confidentiality and comply with the terms of this Order.

         7. 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 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 and their staff, whether retained outside counsel or in-house counsel and employees of counsel assigned to assist such counsel in the preparation of this litigation; (d) court reporters, their staffs, and professional vendors to whom disclosure is reasonably necessary for this litigation; (e) fact witnesses; (f) present or former employees of the producing Party in connection with their depositions in this action; and (g) experts specifically retained as consultants or expert witnesses in connection with this litigation.

         8. Documents produced pursuant to this Order shall not be made available to any person designated in Subparagraph 7(d)-(g) unless such person has first read this Order, agreed to be bound by its terms, and signed the declaration of compliance attached hereto as Exhibit A.

         9. If a party believes in good faith that, despite the provisions of this Protective Order, there is a substantial risk of identifiable harm if particular documents or deposition testimony it designates as "CONFIDENTIAL" are disclosed to all other Parties or non-parties to this action, the producing Party may designate the particular information as "HIGHLY CONFIDENTIAL-ATTORNEY'S EYES ONLY." Information marked "HIGHLY CONFIDENTIAL - ATTORNEY'S EYES ONLY" receive the same protections as "CONFIDENTIAL" information but is further limited in how it may be used or disseminated. Documents or portions of a document marked as ...

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